Business Situation
In response to the EU’s Sustainable Finance Disclosure Regulation (SFDR), a critical initiative for increasing transparency in sustainable investments, the client aimed to:
- Strengthen its environmental, social, and governance (ESG) disclosure framework in line with mandatory and optional Principal Adverse Impact (PAI) indicators
- Enable seamless alignment with Article 8 and Article 9 fund categories under SFDR
- Build a future-proof SFDR compliance infrastructure across 5,000 global companies in 65 sectors
To achieve this, the client partnered with SG Analytics (SGA) for a tech-enabled, expert-driven ESG intelligence solution that combined regulatory interpretation, advanced data mapping, and strategic disclosure enhancement.
SGA Approach
1. Regulatory Interpretation & KPI Framework Development
- Conducted a thorough analysis of the SFDR Regulatory Technical Standards (RTS), interpreting all 18 mandatory and 46 optional PAIs
- Developed a proprietary, regulator-aligned key performance indicator (KPI) taxonomy of 201 indicators, customized to match the client’s global portfolio
- Classified PAIs under Environmental, Social, and Governance dimensions, mapped to themes including:
– Biodiversity, Greenhouse Gas (GHG) Emissions, and Circular Economy
– Human Rights, Diversity, Equity, and Inclusion (DEI), and Labor Practices
– Executive Remuneration, Board Independence, and Anti-Corruption
2. ESG Data Intelligence & Extraction
- Used a hybrid intelligence model by integrating:
– AI-powered ESG data extraction tools (for automated parsing of sustainability disclosures)
– Human validation by ESG domain specialists for nuanced, non-standard disclosures - Analyzed publicly available data from:
– Sustainability reports, regulatory filings, websites, stock exchanges, and policy documents - Mapped indicators at the issuer level and validated trends over multiple reporting years
3. Coverage Universe Execution
- Assessed SFDR-aligned data for 5,000 companies across more than 100 countries and 65 sectors
- Delivered outputs via secure FTP pipelines and direct integration into the client’s platform (via custom APIs and templates)
- Applied data cleansing and harmonization techniques to improve comparability across geographies and formats
4. Disclosure Benchmarking & Peer Analysis
- Conducted multi-dimensional disclosure analysis across:
– Regions, sectors, and peer groups
– Year-over-year progress tracking - Delivered actionable insights to help prioritize outreach and engagement with companies showing low disclosure or weak compliance
5. Strategic SFDR Advisory & Article 8/9 Guidance
- Provided expert guidance on:
– Linking PAI indicators to fund-level reporting under Article 8 and 9
– Mapping governance practices and risk factors with fund documentation - Offered real-time updates on evolving RTS amendments and assisted in methodology recalibration as per regulatory changes
Key Takeaways
PAI-to-KPI Mapping Framework
Developed an end-to-end methodology to interpret, classify, and quantify PAIs using a robust indicator mapping system
Global Sector-Level Execution at Scale
Delivered high-quality, comparable ESG disclosure data across 5,000 companies, driving global consistency in reporting
Expert-Led ESG Interpretation
Human ESG experts ensured contextual clarity in controversial or sector-specific disclosures (e.g., carbon intensity for utilities vs. fintech)
Regulatory Agility and Platform Integration
Enabled integration-ready data delivery across multiple platforms and delivery modes, enhancing the client’s analytics infrastructure
Data-Driven Engagement Strategy
Provided targeted insights on disclosure trends by geography, industry, and company size to support proactive issuer outreach
