Central Bank Expected to Confirm “Fast-Track” Filing Process for Sustainability Disclosures

In our recent briefing “Central Bank issues “Dear CEO” letter on supervisory expectations – key points for asset managers”, we highlighted the Central Bank of Ireland (the “CBI”)’s supervisory expectations for regulated firms in respect of disclosure obligations under the Taxonomy Regulation and the Sustainable Finance Disclosure Regulation (“SFDR”) (here).

By way of update, we understand the CBI plans to issue a notice detailing arrangements for the filing of prospectus updates incorporating the disclosures required under the Taxonomy Regulation and the SFDR 'Level 2' requirements.

This ‘fast-track’ filing process will assist firms meet the impending deadline of 1 January 2022 in respect of disclosure obligations relating to climate change mitigation and climate change adaptation objectives under the Taxonomy Regulation and the deadline of 1 July 2022 for the SFDR 'Level 2' disclosure obligations.

Next Steps

We expect the CBI to issue a notice detailing the ‘fast-track’ filing arrangement shortly. We will monitor developments and provide further updates in due course.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.