On 21 July 2026, the CSSF clarified under Q1 of the FAQ on Sustainable Finance Disclosure that changes to article 8 and 9 SFDR RTS precontractual templates must follow the same regime as any other changes made to the prospectus or issuing document (with some that could be considered as material). Indeed, when included in the prospectus /issuing document, the templates form an integral part of the prospectus/ issuing document. There are no specific requirements in the SFDSR regarding the review of precontractual disclosures made in accordance with articles 8 and 9 SFDR.
As such according to applicable laws and regulations, the prospectus / issuing document including its annexed templates should include the information needed for investor to be able to make a proper judgment of the investment they are making.
Funds that are under the supervision of the CSSF must file any changes to the prospectus/ issuing document via the “e-identification procedure for UCI prospectus and offering documents” (following the same procedure as for other prospectus / issuing document change).
Only material changes according to CSSF circular 14/591 and assessed on a case-by-case basis, must be submitted to the CSSF for review and authorisation. Material changes include, but are not limited to, the below:
- material changes to the fund/ sub-fund in the context of the ESMA guidelines on fund names using ESG or sustainability -related terms,
- changes in the SFDR classification,
- material change in the SFDR criteria set up (meaning strategy, index, methodology, investment objective or material variation in the threshold).
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