12 Jun 2020

The consultation on the Sustainable Finance Disclosure Regulation “SFDR” Regulatory Technical Standards for sustainability reporting is hugely significant for the real estate industry. This will apply to organisations regulated under AIFMD, Solvency II, IORP and other EU regulations. Please look out for the webinar AREF will be holding on this subject in July.

On 23rd April, the three European Supervisory Authorities issued a consultation on the proposed Regulatory Technical Standards (RTS) for ESG disclosure. The regulation to which the RTS relates, the Sustainable Finance Disclosure Regulation “SFDR” was published on 27th November 2019 for sustainability reporting that will apply to organisations regulated under AIFMD, Solvency II, IORP and other EU regulations.  

This is hugely significant for the real estate industry. Fund managers within AIFMD will be caught directly. Others may be caught indirectly through having clients that are regulated under the Solvency II and IORP Directives. 

The reporting provisions are potentially highly problematic for real estate as an asset class as they appear to have been drafted with funds investing in a portfolio of securities in investee companies in mind.

The ESG & Impact Investing Committee and Public Affairs Committee are working together on AREF’s response to this consultation, but would welcome further input from fund managers so please email any comments and thoughts you have on this consultation to Jacqui Bungay. Please let us know who in your organisation is looking at this.

ESMA are holding a public hearing by webinar on ESA’s consultation on SFDR RTS. If you wish to attend you need to register by 25 June here.


John Forbes

John Forbes

Independent Consultant, John Forbes Consulting

John Forbes is an independent consultant advising real estate investment managers, investors and others in the real estate industry in the rapidly changing areas of product development, governance and regulatory matters for real estate funds.  He has advised on the restructuring of high profile open and closed-ended real estate funds in the UK and elsewhere in Europe, as well as the establishment of new funds. He has advised service providers to the real estate investment management industry on the strategic implications of regulatory and other changes.  Prior to setting up John Forbes Consulting LLP in 2013, he spent over twenty-five years with PwC, where he led the firm's Real Estate Industry Practice in Europe, the Middle-East and Africa across all of the firm's services to the real estate industry.

 John is the chairman of the Independent Supervisory Board of the UBS Triton Property Fund, independent chair of the Urban Splash Residential Fund and non executive chairman of Ginkgo Advisor UK Limited.