Jacqueline Jones

SFDR 2.0: issues and implications for private credit

The reform of the EU Sustainable Finance Disclosure Regulation would replace much of the existing product-level disclosure framework with three product categories, each with portfolio thresholds, investment criteria and exclusions. This article considers the implications of the new regime for private credit funds and their managers, including classification, origination, due diligence, borrower information, loan documentation and ongoing monitoring. It also examines the potential wider effects on private credit, particularly the financing of emissions-intensive businesses in transition. As the Commission, Council and Parliament positions enter trilogue, uncertainty remains in several key areas, including applicability to professional-investor-only funds, fossil-fuel exposure, qualifying investments and the practical interaction between regulatory rules and investor expectations.