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)).
EU ESG Ratings Methodology Disclosures
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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Fixed income
Security and transition: How energy is impacting sovereign debt
5 Nov 2026
The low-carbon transition can bolster countries’ energy security, but it can also increase risk in ways that are easy to overlook. Broad indicators are no longer enough to understand the links between energy transition, energy security and sovereign debt risk.
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Natural capital
Natural capital comes of age: Part three: How nature markets will mature
2 Nov 2026
In the third of four articles, we explore the catalysts that can accelerate the process by which nature markets mature, drawing on examples from renewable energy, water rights, carbon markets and forestry.
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Equities
The new realities of investing
30 Oct 2026
Geopolitics, technology and the energy transition are influencing where capital flows, and how investors think about risk, resilience and long-term returns.
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Sustainability
When climate ambition meets reality: What investors are learning about credible transition delivery
19 Oct 2026
Three years into our Climate Stewardship 2030 programme, we are seeing corporate climate strategies being tested for their ability to attract capital, withstand disruption and deliver through changing economic and political conditions.
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Sustainability
Global climate and nature conferences
13 Oct 2026
Climate change and nature degradation are widely recognised as a source of potentially material financial risks, which will increase in the long term. Tackling them requires international cooperation, such as at the Conferences of Parties (COPs) and effective domestic implementation.
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Sustainability
How AI helps advisers navigate Consumer Duty
7 Oct 2026
Dr Andrés Gvirtz of King’s Business School shows how AI can help advisers meet their Consumer Duty obligations and boost their business.
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Natural capital
Natural capital comes of age: Part two: Why not all natural capital revenue streams are created equal
1 Oct 2026
In the second of four articles, we explain how environmental importance does not automatically translate into investment readiness. Investor confidence in future revenues depends on market evidence, contractual certainty and a track record of delivery.
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Sustainability
How Consumer Duty affects sustainability advice
30 Sept 2026
Dr Ylva Baeckström of King’s Business School highlights how regulations can help close the advice gap in terms of clients’ sustainability preferences.
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Private Markets
Revitalising Glen Dye Moor: Real asset stories
28 Sept 2026
In our latest case study, we look at Glen Dye Moor, a 6,300-hectare site in Aberdeenshire, Scotland. We intend to rejuvenate the land, simultaneously removing carbon from the atmosphere, and delivering financial outcomes for investors and social benefits for local communities.
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Private Markets
Building the future
16 Sept 2026
Sustainability-related regulation is becoming an increasingly material driver of real estate investment decision-making, rather than just a compliance requirement. Jeremy Ho analyses the implications.
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Sustainability
Duty calls for advisers
8 Sept 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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Natural capital
Natural capital comes of age: Part one: From environmental value to investment opportunity
25 Aug 2026
In the first of four insights, we explain why natural capital is a foundational input into economic activity. Forests, soils, rivers, wetlands, oceans and biodiversity are productive assets that generate products such as timber or food and are natural regulators of water flows.
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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?