EU Sustainable Finance Disclosure Regulation
The Sustainable Finance Disclosure Regulation (SFDR) is a European Union regulation that came into effect on 10 March 2021 and governs how financial market participants disclose sustainability-related information. SFDR aims to improve transparency and consistency of sustainability-related disclosures, enabling investors to make more informed comparisons between financial products. Sustainability disclosures include information on sustainability risks and, where applicable, environmental, social and governance (ESG) characteristics for financial products, so that investors can assess how sustainability risks are integrated into the investment process.
The information on this page describes our approach to SFDR and includes our policies and procedures, disclosed in accordance with these rules.
Many of our clients are also subject to these requirements. In addition to our disclosures in prospectuses, annual reports and on this website, we will provide our clients with the information they require to comply with their own SFDR obligations.
Background to SFDR and how it impacts Aviva Investors
SFDR is part of the EU’s wider Sustainable Finance framework, which is supported by a broad set of enhanced regulations which apply across the region. The framework includes the Sustainable Finance Action Plan, which aims to promote sustainable investment across the EU, and the EU Taxonomy Regulation, a classification system that defines which economic activities can be considered environmentally sustainable against detailed regulatory criteria.
Product reporting obligations under SFDR
SFDR sets out different disclosure requirements for financial products based on the criteria set out in specific Articles of the Regulation. The characteristics and objectives of a financial product establishes what levels of disclosures need to be made.
Article 9 products have sustainable investment as their objective and are subject to the most detailed sustainability disclosure requirements.
Article 8 products promote environmental or social characteristics, or a combination of these, provided that the companies in which investments are made follow good governance practices. While Article 8 products may make sustainable investments, they don’t necessarily have a sustainable investment goal so they are subject to a corresponding level of disclosure.
Article 6 products do not promote environmental or social characteristics and do not have sustainable investment as their objective. While they may still consider sustainability risks as part of the investment process, they are subject to a lower level of sustainability-related disclosure than Article 8 and Article 9 products and they may not be promoted as funds with sustainability characteristics.
Luxembourg SICAV funds with environmental and/or social characteristics (Article 8 and 9)
Aviva Investors has a wide range of sub-funds that are subject to Article 8 as well as some Article 9 funds. To ensure that underlying investments in these funds align with our relevant commitment to promoting environmental and social characteristics, our investment process includes key sustainability considerations such as ESG screens, sector exclusions and the integration of ESG insights.
We also undertake stewardship activities. Our firm-wide approach to stewardship is to engage with stakeholders at multiple levels in the financial system, including with policymakers and regulators, with the aim of maximising long-term value for investors – we call this ‘holistic stewardship’. These activities are aligned to Aviva Investors’ overarching approach to sustainability.
For further information regarding these funds, please see the documentation available at our fund centre, linked below. Detailed pre-contractual information can be found within the fund prospectuses or in the website disclosure section of this webpage.
Website product disclosures
For financial products that promote environmental or social characteristics, financial market participants are required to publish specific product disclosures for funds subject to Articles 8 and 9 of SFDR (as set out in Article 10(1)).
Remuneration
To meet the requirements set out under Article 5 of the SFDR, we have published additional information on remuneration and ESG in our IFPR Disclosures.
Sustainability Risk Policies
Private Markets Sustainability Risk Policy
This policy describes how we integrate sustainability considerations into each asset class investment process across Private Markets. Private Markets covers real estate debt and equity, infrastructure debt and equity, private corporate debt and structured finance, venture, growth and natural capital.
Public Markets Sustainability Risk Policy
This policy describes how we integrate sustainability considerations into each asset class investment process across Public Markets. Public Markets includes Fixed Income, Equities and Multi-Asset funds. Examples include funds managed by Aviva Investors that primarily invest in equities and bonds, as well as money market funds.
Aviva Investors Luxembourg Sustainability Risk Policy
Aviva Investors Luxembourg (AILX) recognises and embraces its duty to act as long-term stewards of clients’ assets, maintaining a deep conviction that environmental, social, and governance (ESG) factors can have a material impact on investment returns and client outcomes. This policy includes the key pillars of AILX’s ESG approach including consideration of sustainability risk and how they apply to the funds we operate.
Please see this page for related policies and documents.
Responsible investment views
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Sustainability
Duty calls for advisers
8 Sep 2026
Changes to regulations and consumer expectations are transforming the landscape for financial advisers, according to Marc Lepere.
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Equities
UK and EU sustainability regulations: Could a narrow focus be missing the bigger picture?
27 Aug 2026
Regulation must recognise that sustainable investing incorporates more than the provision of sustainable funds alone.
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Equities
2026 AGM season
10 Aug 2026
As AGM season winds down, we examine the key trends that influenced resolutions and outline our core principles for voting.
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Equities
Driving stewardship together
29 Jul 2026
Aviva’s Investments, Wealth and Retirement business and Aviva Investors are working together to deliver financial and sustainable outcomes, connecting clients to their capital.
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Fixed income
Taking the leap: Incorporating climate in core investment-grade allocations
16 Jun 2026
How can investors align their credit allocations to net-zero commitments and maintain returns?
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Equities
Confidence in a changing climate
15 Jun 2026
How can institutions forge impactful climate strategies that are right for them and their end beneficiaries? Our “Confidence in a changing climate” guide showcases some of the solutions we have developed to help.
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Equities
Sustainability review 2025
2 Jun 2026
We believe understanding sustainability factors and trends is fundamental to effective asset management. This report sets out our approach and includes an overview of our holistic stewardship activities over the past year
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Private Markets
Solid foundations: Delivering social value to unlock investment value
26 May 2026
Supporting employment, skills and training opportunities for local people produces lasting social value. But it is also key to delivering long-term investment returns.
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Sustainability
Infrastructure equity Q&A: Uniting innovation and rigour
3 Feb 2026
Angenika Kunne outlines Aviva Investors’ infrastructure equity strategy and the key themes driving origination, management and value creation.
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Sustainability
UK low-carbon policy: What to look out for in 2026
27 Jan 2026
Aviva’s Nick Molho looks at this year’s policy priorities and likely developments for the UK’s low-carbon agenda, and reflects on what it means for investors.
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Sustainability
Cities of the future: What will cities look like in 2050?
8 Jan 2026
Today’s private market investments will shape 2050 cities. We explore what this could look like, and the related challenges and opportunities.
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Fixed income
Buy and maintain credit: Taking the road to net zero
15 Dec 2025
Long-term trends like climate change are particularly important for buy-and-maintain investors. How can they integrate climate objectives, such as net zero by 2050, into their portfolios?
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Equities
Boosting low-carbon investment in the UK: 2025 Roadmap Update
11 Dec 2025
In 2024, we outlined our view on the most important public-policy interventions to unlock private investment in the low-carbon economy. In this update, we take stock of policy developments since, and look ahead to 2026 and beyond.
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Sustainability
Navigating nature: Opportunities for the investor of tomorrow
10 Dec 2025
Our society, economies and financial systems are embedded in nature, not external to it. This paper sets out the actions we are taking to understand nature-related risks and opportunities to deliver outcomes that meet our clients’ needs, and to support nature-related global goals.
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Sustainability
Aviva Investors’ Social Value Label: Recognising achievements during construction
11 Nov 2025
The newly launched Aviva Investors’ Social Value Label recognises quality practice in the construction supply chain. It will be awarded to contractors who deliver social value when building commercial real estate.
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Sustainability
A tale of two priorities: Aligning financial flows to climate mitigation
30 Oct 2025
Financial flows shall be “consistent with low greenhouse-gas emissions and climate-resilient development”, according to Article 2.1.c of the Paris Agreement. Yet most finance continues to flow to business as usual. How can this change?