FinDatEx publishes the European MiFID Template version 3.1 (EMT v3.1) compatible with SFDR

On Friday 12 February 2021, FinDatEx validated version 3.1 of the new European Markets in Financial Instruments Directive (MiFID) template (EMT). Changes from EMT v3 include information related to Sustainable Finance Disclosure Regulation (SFDR) level 1 requirements for investment funds.

What is the implementation timeline?

EMT v3.1 is a temporary version that goes live on 10 March 2021, the application date of the SFDR. FinDatEx plans to review this version again when the MiFID II delegated acts on environmental, social and corporate governance (ESG) integration are published and the SFDR regulatory technical standards (RTS) are approved.

What does it mean for asset managers?

Asset managers will need to disseminate both v3 and v3.1 from 10 March 2021. FinDatEx recommends that both versions coexist as they cannot be merged until a new version is defined when the relevant legislation is published.

What has changed from EMT v3?

The main change is on the EMT target market for all countries:

• Field “05105_Intended_Compatible_With_Clients_Having_Sustainability_Preferences” has been modified. It can now be completed with “Neutral”, “C” or “O”. The “C” code relates to funds pursuant to Article 8 of the SFDR and the “O” code relates to funds pursuant to Article 9 of the SFDR.

Two country-specific sections have been added:

• The first section is on “additional product information required for distribution in Germany (as an ESG product)” and includes three fields to provide more details on the ESG category; the focus of the strategy between E, S and G; and the ESG label or standard used.
• The second section is on “additional product information required for the French market, by the French regulator AMF” and includes a field to provide more details on the AMF doctrine used as per AMF position/recommendation 2020-03.

How can Deloitte help?

Deloitte produces and disseminates over 200,000 EPT and EMT documents annually and can help you implement EMT v3.1. Do not hesitate to contact our specialists below for more information or if you have any questions.

With our Regulatory Watch Kaleidoscope service, Deloitte can also help you stay ahead of the regulatory curve to better manage and plan upcoming regulations.

The official communication from FinDatEx can be found here.

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