This article concerns the product classification system of the SFDR into Articles 6, 8 and 9.
SFDR: Article 6 (gray)
For article 6, what is required is at a minimum compared to other Fund classifications (i.e., Articles 8 and 9). Article 6 funds do not have a sustainability scope.
Each article 6 fund shall have consideration of sustainability risks by at a minimum including an exclusion list. The fund must explicitly mention that the fund is classified as Article 6 and does not consider sustainability factors.
SFDR: Article 8 (light green)
Article 8 funds are a fund type in-between articles 6 (no ESG consideration) and 9 (sustainable investment objective). These funds promote environmental and/or social characteristics and have good governance principles, along with other non-ESG traits. Contrary to Article 9 products, sustainable investment is an aspect of the investment process rather than its objective.
In Article 8 or otherwise called the 'catch-all category' according to Morningstar, funds with a variety of asset classes and ESG approaches are included. These products could have a screening in place for environmentally or socially harmful investments or ESG ratings as part of the investment decision-making.
Article 8+ (mid-green): These types of funds are classified as Article 8 funds but include a minimum proportion of sustainable investments.
SFDR: Article 9 (dark green)
Article 9 funds are the highest category of ESG consideration. These funds must have a social and/or environmental sustainable investment objective. Additionally, these products must show compliance with the ‘do no significant harm’ (DNSH) principle towards any of the EU Taxonomy objectives.
Overview of Article 6, 8 and 9 Requirements
For the overview of the different requirements amongst the three fund types, please see below:
PAIs and EU Taxonomy?
How are the product-level distinctions from the SFDR related to PAIs and the EU Taxonomy?
What about Article 8+ products?
An 'Article 8+ product' is an unofficial category that rose from the SFDR fund classification to denote Funds which have sustainable characteristics.
The '+' stems from their additional ambition to allocate a share of the Fund to meeting a sustainable objective, much like the ambitions of Article 9 products (with lower thresholds however).
This category can therefore be seen as a combination of the two classifications (namely Article 8 and Article 9 products).
To prove that your Fund is an Article 8 product, you need to prove that you invest in 'sustainable investments', which generate turnover from 'sustainable economic activities'.
This must be proven through the 'sustainable investment' framework, requiring to showcase a i) 'substantial contribution' to a sustainable objective, ii) that the activity 'does not significantly harm' ('DNSH') any of the remaining sustainable objectives, and iii) that it meets the minimum safeguards on human rights and other social aspects.
To prove this, either the PAI framework (for proving the DNSH is met) or the EU Taxonomy to perform the entire assessment will be required.