Following a period of intensive law-making where we saw the adoption of the Sustainable Finance Disclosure Regulation ("SFDR"), SFDR Level 2 requirements, the EU Taxonomy Regulation and the application of the Packaged Retail and Insurance-based Investment Products ("PRIIPs") Regulation to UCITS, the focus over the course of 2023 shifted to implementation and future developments. A number of EU and domestic consultations have issued, many of which remain open or the outcomes of which remain unclear.

We have yet to see final guidelines following the European Securities and Markets Authority ("ESMA") consultation on funds' names using ESG or sustainability-related terms, (now expected in Q1 2024). We await the outcome of the European Supervisory Authorities' ("ESAs") consultation on changes to Level 2 measures under the SFDR and the Irish Department of Finance's consultation "Funds Sector 2030" on the future development of the funds industry in Ireland, while the European Commission ("Commission") consultation on the review of the SFDR remains open until 15 December 2023.

In relation to legislative change, the negotiations to finalise amendments to the Alternative Investment Fund Managers Directive ("AIFMD") have continued following political agreement in July of this year, while the Commission's sustainable finance package published in June sought to provide more clarity to assist with implementing the legislative requirements, particularly with respect to the EU Taxonomy Regulation, and included a proposal to regulate ESG rating providers.

We have set out below a brief review of some of the key developments since our Horizon Tracker Summer 2023 and some thoughts on what lies ahead in 2024.

KEY THEMES IN ASSET MANAGEMENT & INVESTMENT FUNDS