What are Article 8 and Article 9 products under the SFDR?

The **disclosure regulation SFDR (Regulation (EU) 2019/2088)** requires financial market participants to make product-level sustainability disclosures. **Article 8** covers products that **promote environmental or social characteristics**; **Article 9** covers products that have **sustainable investment as their objective**. The gradation determines which pre-contractual and periodic disclosures are required ^[1].

Important: these are **disclosure categories, not state quality labels**. The market shorthand 'Article 8 fund', 'Article 9 fund', 'light green' and 'dark green' does **not** appear in the text of the regulation — the SFDR governs only transparency duties, not a product authorisation. This very conflation of disclosure and label is a common compliance error.

The format is not optional: **Delegated Regulation (EU) 2022/1288 (the SFDR RTS)** contains the mandatory templates for the pre-contractual and periodic disclosures of Article 8 and Article 9 products (Annexes). It interlocks with the **PAI disclosures** (principal adverse impacts) and with the Taxonomy Regulation where a product reports an environmentally sustainable investment share ^[1][2].

On **20 November 2025** the Commission tabled a proposal to revise the SFDR (**COM(2025) 841**). It would replace the Article 8/9 logic with a **category/label system** — three categories (**Sustainable, Transition, ESG Basics**), each tied to a **70% portfolio threshold** and common exclusions. **As of 2 June 2026 this is only a proposal in the ordinary legislative procedure — not adopted**, with application expected no earlier than 2027/2028 ^[3].

In practice this means: **Articles 8 and 9 remain the operative regime until further notice.** Switching your product classification and disclosure to the proposed categories now bets on an act not yet passed. Not to be confused: the proposed 70% threshold of the SFDR categories is a different figure from the binding 80% threshold of the ESMA guidelines on fund names.