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EN ANNEX

1 EN ANNEX Question related to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation 2019/2088) ESA: ESMA, EIOPA and EBA Question ID: Regulation reference: Regulation (EU) 2019/2088 on sustainability related disclosures in the financial services Topic: sustainable finance disclosures Article: points (1) and (4) of Article 2 1. Question Does Regulation (EU) 2019/2088 (SFDR) apply to registered (sometimes referred to as sub-threshold) AIFMs referred to in Article 3(2) AIFMD? 2. Answer It follows from points (1) and (4) of Article 2 Regulation 2019/2088 that for the purposes of the Regulation a financial market participant comprises an alternative investment fund manager , as defined in point (b) of Article 4(1) of Directive 2011/61/EU1, including those which have their registered office in a Member State (EU AIFMs) and those which have their registered office in a third country (non-EU AIFMs).

3 ESA: ESMA, EIOPA and EBA Question ID: not available Regulation reference: Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services Topic: sustainable finance disclosures Article: Article 4(3), Article 4(4), point (a) of Article 4(1) 1. Question As regards Article 4(4) of Regulation 2019/2088, must the calculation of the 500-employee threshold

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