EU Sustainable Finance Disclosure Regulation
The EU Sustainable Finance Disclosure Regulation (SFDR) is a set of European Union rules that came into effect on March 10, 2021, with the goal of making the sustainability profile of funds more comparable and easier to understand for investors. They categorise products into specific types and include metrics for assessing the environmental, social and governance (ESG) impacts of the investment process for each fund.
As the name suggests, this regulation emphasises disclosure. 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 will also be subject to these requirements. Apart from our disclosures in prospectuses, annual reports and on this website, we will provide our clients with the information they need to comply with SFDR.
Background to SFDR and how it impacts Aviva Investors
SFDR is part of the EU’s wider Sustainable Finance framework, which is backed by a broad set of enhanced regulations that are applied across the region. The framework includes the Sustainable Finance Action Plan, which aims to promote sustainable investment across the EU, and a Taxonomy to categorise economic activity through a sustainability lens aimed at creating a more level playing field across the region.
Product reporting obligations under SFDR
The most visible and impactful aspect of SFDR is the reporting format funds and mandates will need to follow based on Articles 8 and 9. In addition, those funds that do not integrate any kind of binding sustainability constraints into their investment process, or have a sustainable investment objective, are subject to Article 6. While these funds are still allowed to be sold in the EU, they may not be promoted as funds with sustainability characteristics.
Article 8 products promote environmental or social characteristics, or a combination of those characteristics, provided the companies in which investments are made follow good governance practices.
Article 9 covers products targeting sustainable investments and those that have sustainable investment as their objective.
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.
Asset Class Sustainability Risk Policies

Private Markets Responsible Investment and Sustainability Risk Policy
This policy describes how we integrate sustainability considerations into each asset class investment process. Private Markets covers traditional real estate products and our alternatives business including infrastructure equity and commercial property/private market debt.

Public Markets Responsible Investment and Sustainability Risk Policy
This policy describes how we integrate sustainability considerations into each asset class investment process across Public Markets, which includes Credit & Equities (funds managed by Aviva Investors that primarily invest in equities and bonds and includes money market funds) and Multi Assets (including Multi-Strategy, Multi-Asset ranges, Fund of Funds, Liability Driven Investment, Global Convertibles).
Please see this page for related policies and documents.

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.
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 and 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 prospectus and the SICAV Impact Assessment Matrix below. Detailed pre-contractual information can be found within the prospectus 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)).
Responsible investment views
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Equities
The power of governance: Our key takeaways from the 2025 AGM season
20 Aug 2025
While fewer shareholder resolutions were tabled at company AGMs, we continued to encourage high standards of corporate governance practice, recognising individual company context and the importance of long-term value creation.
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Responsible Investing
Show me the value: Investing in carbon removal, part three
11 Jul 2025
In this article, we explore the potential benefits of carbon removal strategies for institutional investors.
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Real Assets
MegaTRENDs: Why TRENDs matter for investing in private markets
27 Jun 2025
A set of megatrends is reshaping the world, creating new opportunities and risks for investments in private markets.
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Equities
Decarbonising agriculture: Unlocking investment in sustainable land use
17 Jun 2025
Agriculture is integral to reaching net-zero emissions and reversing nature loss. Its transition also presents huge investment opportunities. We held a roundtable of experts to discuss challenges and solutions.
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Responsible Investing
Show me the value: Investing in carbon removal, part two
2 Jun 2025
In this article, we explore the different types of carbon credits, the development of the markets on which they are bought and sold, and how institutions can use them to achieve their investment and sustainability goals.
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Responsible Investing
Show me the value: Investing in carbon removal, part one
28 May 2025
New markets are emerging to enable institutions to invest in nature and potentially achieve sustainability-related objectives alongside key financial outcomes.
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Fixed income
Sovereign engagement: Driving positive change while delivering long-term value
14 May 2025
Investor engagement with governments on their climate commitments can be a powerful complement to other forms of stewardship. It can also help investors identify opportunities and mitigate risks, says Thomas Dillon.
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Responsible Investing
Climate Stewardship 2030 programme
29 Apr 2025
Designed to support our holistic stewardship approach, Aviva Investors adopted its Climate Stewardship 2030 programme (CS30) in 2024.
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Responsible Investing
Decarbonising power: Challenges and solutions
28 Apr 2025
Decarbonising power is essential to provide affordable, clean energy and deliver net zero ambitions. It also brings significant investment opportunities. We convened a range of industry experts to discuss the barriers and how to overcome them.
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Economic Research
2025 voting trends: Four themes to watch
17 Mar 2025
As AGM season gets under way, we look at the key trends that will shape resolutions and lay out our guiding principles for voting.
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Economic Research
Transition finance: How the UK can lead as transition finance reshapes investing and economies
18 Feb 2025
As a member of the UK’s newly formed Transition Finance Council, Mark Versey explains why and how a transition finance lens can transform investing.
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Economic Research
Decarbonising buildings: Five barriers and how to overcome them
28 Jan 2025
The built environment generates almost two-fifths of global emissions, but decarbonising the sector will require a coordinated effort. We brought together experts across the value chain to discuss shared challenges and solutions.
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Fixed income
Can credit hold firm in 2025? The outlook for investment grade credit and climate transition
24 Jan 2025
Credit spreads remained largely immune to turbulence in 2024 despite concerns for a reacceleration in inflation, an unprecedented scale of global elections and volatility on economic data and changing rate cut expectations. Where to in 2025?
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Responsible Investing
Infrastructure debt in 2025: Investor research and discipline are key to unlocking value in the sector
23 Jan 2025
European infrastructure debt issuance should pick up as governments look to stimulate their economies and support the energy transition. But with banks keen to fund some of the best opportunities, investors need to maintain their discipline.
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Fixed income
40 years of lending lessons: How four decades in real estate debt has shaped Aviva Investors’ approach
12 Dec 2024
From navigating market crashes to embracing ESG and technology, Adrian Poole and Gregor Bamert reveal how 40 years of real estate debt investing have moulded Aviva Investors’ strategy – and what it takes to stay ahead in a rapidly changing market.
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Equities
What’s next for nature? Key takeaways from Biodiversity COP16
11 Dec 2024
Following our participation at COP16, the 16th meeting of the Conference of the Parties to the UN Convention on Biological Diversity, we reflect on the key themes that emerged, outstanding challenges, and what this all means for investors.