Where have all the dark-green funds gone?
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Where have all the dark-green funds gone?

Asset managers are spooked by mandatory disclosure regulations coming into force in January. This is good news for the anti-greenwashing campaign, not so much for biodiversity lovers.


Shortly after the dust had settled in Sharm El Sheikh and COP27, and some 9,000 kilometres west of the Sinai desert, Montreal was hosting COP15, the United Nations Biodiversity Conference. It was the first time the conference had been held since 2018. It aims to implement the protocols of the Convention on Biological Diversity (CBD) and the post-2020 biodiversity framework.

While biodiversity stakeholders demand increased capital flows into nature, the reality of regulatory changes on the other side of the Atlantic could deter managers from launching dark-green products in the future.

The EU’s Sustainable Finance Disclosure Regulation (SFDR) will become mandatory on January 1, 2023. Confusion around what SFDR counts as a sustainable investment and how to prove it could disincentivize managers from launching ambitious products for biodiversity gains (or at least no net loss).

Better safe than sorry

In reaction, the fund universe has seen a wave of voluntary declassifications from the world’s biggest asset management houses, including Blackrock, Amundi, Deutsche Bank AM, and BNP Paribas AM. Many of their Article 9 funds – which must include 100% of sustainable investments as defined by Article 2.17 of the SFDR – are being downgraded to Article 8, or funds that merely promote environmental, social and governance characteristics.


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