The SFDR review and what does not change for private equity managers

The review does not remove the need for data

The November 2025 proposal aims to simplify SFDR and make product categories clearer. Managers will still need investee adverse-impact data, documented decisions and support for investor disclosures.

PAI starts at the investee

The strongest data originates at the investee, linked to its VSME, footprint and evidence. Other investees can answer a minimum request or be imported with declared source and methodology.

EVIC, attribution and four snapshots

Aggregation requires positions and EVIC at four quarterly snapshots, attribution factors, coverage and declared estimates. An annual average without stored snapshots cannot be rebuilt.

Data governance, traceability, consistency between entity and product disclosures, and DNSH controls remain essential. Voombu records and validates the manager's decisions; it does not classify products or define sustainable investment.