SFDR Article 9: Is It All About Impact?

Abstract

We investigate more than 1,000 investment funds that are classified under Article 9 of the EU Sustainable Finance Disclosure Regulation (SFDR). Using a new typology of sustainable investments, we show that Article 9 funds pursue varying degrees of ambition: while 60% of funds follow an impact-oriented investment strategy, we identify 40% that are not impact-related but rather pursue an Environment, Social, and Governance (ESG) investment strategy. Generally, we do not find significant differences in ESG scores and returns between ESG-related and impact-related funds. Yet, impact-related funds have higher SDG impact scores and higher management fees than ESG-related funds. Downgraded Article 9 funds, i.e., funds that changed SFDR status by January 2023, however, tend to follow less ambitious investment approaches and realize lower returns than funds that maintained their SFDR statuses. Overall, this finding suggests that downgraded funds can be considered inferior to non-downgraded funds.

Keywords: SFDR, ESG investing, impact investing

JEL Classification: G11, G18, G23, M14