SFDR Article 6, 8 and 9: what each disclosure category means for your funds

Understand the differences between the three SFDR disclosure categories: what sets an Article 6 fund apart from an Article 8 or 9 fund, and how private equity managers justify the category of their funds to LPs.

In brief

•Article 6: the fund does not promote sustainability, but must explain how it integrates sustainability risks.
•Article 8: the fund promotes environmental or social characteristics and invests in companies with good governance practices.
•Article 9: the fund has sustainable investment as its objective, with DNSH and governance demonstrated.
•None of the three is a label awarded by a regulator. It is a self-declaration by the manager, which must be backed up by data.

What each category promises to LPs and what the manager must demonstrate

An international LP receiving information on three funds with different disclosure categories wants to understand, first of all, how the investments align with its own ESG objectives. The first reading tends to be hierarchical, with Article 9 seeming “better” than Article 8, which in turn seems “better” than Article 6, and the question comes up in fundraising due diligence, annual reviews and ESG questionnaires. For the European private equity manager, the challenge is twofold: to meet the legal requirements of the SFDR and to demonstrate the value generated and the alignment with what the LP is looking for.

The SFDR was designed as a transparency regime, so the categories describe the promise made to the investor and the information that backs it up; they do not work as a quality scale, a regulatory label or a certification of the fund.

For whoever leads sustainability at a private equity firm, the challenge lies in explaining that difference in a few lines and proving it with data from the portfolio companies, almost always collected by hand and in different formats. It is therefore worth having a short, consistent and documented answer.

The 30-second answer

Article 6 says the fund considers ESG risks, Article 8 says it promotes environmental or social characteristics with binding elements, and Article 9 says the fund’s objective is to invest in activities that contribute to an environmental or social objective without causing significant harm.

In our case… (we suggest you describe your own case)

What distinguishes each disclosure category

Article 6: integration of sustainability risks

It applies to funds with no sustainability promise. Even so, the manager must disclose in the pre-contractual documents how it integrates sustainability risks into the investment decision and what the likely impact on returns is, or explain why it does not consider them relevant.

Many private equity funds fall into this category and may go no further than carrying out an ESG due diligence on acquisitions, since assessing ESG risks does not mean promising sustainable characteristics.

Article 8: promotion of environmental or social characteristics

It is the most common category among funds that integrate ESG in a structured way. The fund must define the characteristics it promotes and the binding elements that put them into practice, such as exclusion lists, minimum performance thresholds or KPIs to be met by the portfolio companies, as well as ensuring good governance practices in the companies invested in. It may also commit to a minimum proportion of sustainable investments.

"Article 8+" is a market expression and not an official SFDR category, so the specific commitment must be declared by the fund itself.

Article 9: sustainable investment objective

It requires sustainable investment to be the fund’s objective. Each investment must contribute to an environmental or social objective, respect the principle of doing no significant harm (DNSH) to the environment and society, and comply with good governance practices. According to the European Commission’s 2023 clarifications, the vast majority of the investments of an Article 9 fund are expected to meet that definition.

Certain investments are allowed for specific purposes, such as liquidity or hedging, provided that they have minimum environmental or social safeguards and are consistent with the fund’s objective.

Criterion	Article 6	Article 8	Article 9
Promise to the investor	Integrates sustainability risks	Promotes environmental or social characteristics	Has a sustainable investment objective
Sustainable investment	Not required	Optional; if there is a commitment, the fund declares the minimum proportion	Required, with limited exceptions (liquidity, hedging) subject to minimum safeguards
DNSH and governance	Not applicable	Governance required; DNSH for sustainable investments	Required for all sustainable investments
EU Taxonomy	Statement that it does not consider the Taxonomy criteria	Discloses the proportion aligned with the Taxonomy	Discloses environmental objective and alignment
Documentation	General disclosures in the prospectus and on the website	Annexes II and IV, website	Annexes III and V, website
Data requested from portfolio companies	Material ESG risks (may be assessed by the management entity)	KPIs for the characteristics promoted, PAI	Evidence per investment: contribution, DNSH, PAI, Taxonomy
Greenwashing risk	Low — no green claim to overstate	Highest — the broad standard is easy to interpret too loosely	Low — but some funds have been reclassified for not being able to prove the requirements

In all three categories, the principal adverse impacts (PAI) and ESMA’s guidelines on fund names limit what the manager can say and what the fund can be called.

How to choose and justify the category: five steps

1. Start from the fund’s real strategy. Gather what the constitutive documents and fundraising materials already promise, because the disclosure category must reflect what the team actually does.

2. Define measurable binding elements. Exclusions, thresholds and KPIs with a value, a deadline and an owner, so that an LP or auditor can verify them.

3. Confirm what the portfolio companies can report. Many portfolio companies already apply sustainable practices, such as energy audits or safety management systems certified to ISO 45001, but the information is generally scattered. A common ESG data checklist solves most of the gaps. For companies with fewer than 1,000 employees, the VS (Voluntary Standard, formerly VSME), the voluntary European standard, helps organise that collection, although it is not, in itself, an SFDR obligation. The Comprehensive module adds 9 disclosures to the Basic module (11 disclosure requirements), making 20 disclosure requirements in total, including some PAIs.

4. Test Article 9 investment by investment. Document the objective, the contribution, the DNSH analysis, the taxonomy and the governance of each portfolio company before assuming the classification.

5. Align documentation, name and communication. Check that the prospectus, the annexes, the website and the presentations all say the same thing and that the fund’s name complies with ESMA’s guidelines.

And SFDR 2.0?

The Commission’s proposal of November 2025 replaces Articles 6, 8 and 9 with product categories: Transition (Article 7), ESG Basics (Article 8) and Sustainable (Article 9), with a threshold of 70% of investments aligned with the strategy. The Council has adopted its negotiating mandate and the Parliament has approved the mandate to negotiate, but the reform is still pending and may change.

The mapping will not be automatic: an Article 8 fund may end up in ESG Basics or in Transition, depending on the final criteria, and funds that are closed and fully raised before the rules apply fall, under the proposal, outside the new regime.

Practical examples

The following scenarios are illustrative and do not identify specific funds or managers.

Industrial buyout fund in the Article 8 category

A fund that invests in mid-sized industrial companies promotes decarbonisation and workplace safety. The binding elements include an exclusion list, the measurement of Scope 1 and 2 emissions across all portfolio companies and a reduction target set for the first year of ownership. Periodic reporting is based on data collected from each company using the same template.

Energy efficiency impact fund in the Article 9 category

An energy efficiency impact fund classified under Article 9 must demonstrate, for each investment that forms part of its sustainable objective, how it contributes to the climate objective, does not significantly harm other environmental or social objectives (DNSH) and respects good governance practices. It must also assess the economic activities financed against the EU Taxonomy criteria and disclose the proportion of investments that is actually aligned. Investing in a company in the energy efficiency sector does not, on its own, demonstrate that alignment. The due diligence must therefore gather evidence for each of these assessments and feed the fund’s reporting.

Article 6 fund with ESG due diligence on acquisitions

A generalist fund with no sustainability promise analyses climate and supply chain risks before each acquisition and makes the result available to the investment committee. This meets Article 6 and leaves the manager better prepared for a potential repositioning in a future fund.

Quick wins for this week

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Write the 30-second answer with information on each fund and have it validated by the legal team.

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List, for each fund, the binding elements promised and who provides the data for each one.

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Send the portfolio companies a single ESG collection template instead of separate requests.

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Compare the name, annexes, presentations and website content of each fund to spot inconsistencies.

What Sustanya offers

Sustanya combines specialist ESG consulting for private equity with a multi-entity platform that consolidates portfolio company data.

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Standardised collection of ESG data from portfolio companies, with tracked deadlines and links to supporting documentation.

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ESG due diligence on acquisitions and maturity assessment of portfolio companies.

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SFDR reporting and responses to LPs from the same data set.

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ESG strategy and acceleration of sustainability implementation in portfolio companies, including the smaller ones.

Explore the Sustanya platform demo and see how to consolidate your portfolio’s ESG data.

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