SFDR, IFR and the rest
A register for what you publish in your own name.
Sustainability and prudential disclosures, remuneration, governance, complaints, terms. They are replaced rarely and referenced for years, which is exactly when nobody can say what the previous wording was, when it changed, or what applied on the date somebody is asking about.
- SFDR Article 4
The statement on principal adverse impacts is published and maintained on the website, by 30 June each year for the preceding calendar year, and carries a comparison with earlier reference periods.
- SFDR Article 12
What is published under Articles 3, 5 and 10 is kept up to date, and where it is amended, a clear explanation of the amendment is published on the same website — with the date of publication and the date of any update stated.
- IFR Article 46
A firm outside the small and non-interconnected category discloses on the same date as it publishes its annual financial statements, in one medium or location where possible, with a reference in each medium to the synonymous information in the others.
- IFR Articles 47 to 53
Governance, own funds, risk management, remuneration policy, investment policy and environmental, social and governance risks — a set that is republished every year rather than written once.
We do not read any of this for you, and we take no view on whether you have met it. What we note is narrower: kept up to date, a clear explanation of the amendment, the date of publication and the date of any update, a reference to the synonymous information in the other medium — those are the words of a record, and a folder on a website has nowhere to put any of them.
What hangs where
The firm, and the products it sells.
Two levels, because that is how many there are. A document is attached to the firm or to a product. The attachment decides where the document is shown and how it is grouped. It does not decide the address: every document has its own, unchanged by anything that happens to the structure around it.
Each language version is a document in its own right, with its own address and its own publication date. Periodic disclosures are separate too: this year's statement is not a new version of last year's, and both remain current for their period.
The firm. Published in your own name, and expected to be current rather than merely present.
/d/example-capital-sustainability-risk-policy-en- Sustainability risk policySFDR Article 3
- Statement on principal adverse impactsannual, by 30 June
- Remuneration policy and its disclosureSFDR Article 5 · IFR
- Prudential disclosuresannual, with the accounts
- Complaints handling and its formper language
- Terms, order execution and conflicts of interest
A financial product. What is published per product, and referenced from the documents that describe it.
/d/example-capital-strategy-sustainability-en- Sustainability-related disclosuresSFDR Article 10
- Pre-contractual annexesone per language
- Periodic reportsone per period
An amendment is explained, not just made
The wording changes, the explanation is published alongside it, and both carry a date. The register records when the new version took effect and keeps the previous one at its own dated address — so the explanation has something to point at, and the file it describes has not been overwritten.
A comparison needs its sources
A statement that compares this reference period with earlier ones is only as good as the earlier statements. Each year's is a publication of its own, kept at its own address, rather than a file that was replaced each June and now exists in one version.
Where the address ends up
One location, and the references to it.
The rules ask for the disclosures to sit in one place and for the other places to point at it. That makes the address a piece of published information in its own right — and one you cannot revise everywhere once it has been written down.
- The other medium
Where the same information appears in more than one place, each place carries a reference to the other. Those references are addresses, and they are written once.
- Pre-contractual documents
They point at the website for what is disclosed there, and they are printed, circulated and kept by people who will not be told when a wording changes.
- Client agreements and terms
The version a client agreed to is a question that gets asked years later, usually by someone who is not asking casually.
- Your annual report and your filings
Published on a date, referring to information that keeps changing after that date.
- Whoever asked you for the link last
A distributor, a professional client, a counterparty in a due diligence. None of them will ask again.
None of them are ours, and we do not submit anything to any of them. What a permanent address does is make the copies harmless: they were written once and they stay correct, because the address answers with whatever version is current rather than with whatever file was uploaded last.
Documents are served from your own domain by CNAME, as standard rather than as an upgrade, so the referenced address sits on your own host name. Rename a document and the previous address keeps answering — permanently, and without a redirect, because a redirect is what makes a recipient record the wrong address.
The portal gives you the other half of it: one page per publisher, listing what is published and when it took effect. It is the location to point at when someone asks for one, and it stays correct without being maintained.
Scope
A register, not a place to keep policies.
The line matters more here than anywhere else, because the documents look like the ones a policy tool holds. It is the same line as everywhere else in the register: the document already exists, and we keep the record of its publication.
Drafting, review cycles, approval routing, review dates, staff attestations and mapping to a rulebook are policy management. That is a mature category with capable suppliers, it is bought by a different person for a different reason, and it is not what this is. We begin where it ends: an approved document, ready to be published.
Which means the internal version of a policy — the one with tracked changes and the approval date — is none of our business. What we hold is the version you published, the day it took effect, the day it stopped applying, and the file itself, byte for byte, with its hash recorded on arrival.
Not drafting, reviewing or approving a document
Not deciding whether a review is due, or when one is
Not collecting attestations from your staff
Not mapping a document to a rule or an obligation
Not an intranet, and not a place your staff log in to read
Getting started
Start with the page you point people at today.
Most firms have one: a page of links, added to over the years, where the disclosures live. A good first step is that page — the documents on it as they stand, the earlier versions where you still have them, and the dates they took effect. It is small enough to set up in an afternoon and complete enough to judge: the addresses, the version history and the answer to a date, on your own domain, with your own files.
How the setup runs, what the register records and where our responsibility ends is written out on the front page. The demonstration portal is set up for a fictional fund manager rather than an investment firm, because that is the vertical we started in; the register behind it is the same one.