Colibri AM
Colibri AM Asset Management — responsible investment distribution
Series Insights Topic SFDR Articles 6/8/9 Date Jan 2026 Type analytical note

SFDR Articles 6/8/9: what the classification does (and does not) say

In practice, SFDR classification is a disclosure framework. It helps standardise information, but it is not, by itself, a full judgement on “quality” or “impact”.

Premise

Professional stakeholders use SFDR as an entry point for comparison. The classification helps structure questions, but due diligence generally goes beyond the label to evaluate methodology, governance, and reporting consistency.

What it is

A disclosure frame A way to describe sustainability characteristics/objectives and how they are pursued and monitored.
A vocabulary constraint Terms should be used consistently with the product documentation and the applicable reporting expectations.
A comparator It enables first-pass comparison, not final judgement.

What it is not

Not a ranking Article 9 is not automatically “better” than Article 8; it indicates a different disclosure framing and objective structure.
Not proof of outcomes Classification does not, by itself, prove real-world impact outcomes; it sets expectations for how objectives are defined and reported.
Not a substitute for process Methodology and governance still have to be evaluated: definitions, controls, escalation, and record keeping.

Typical diligence questions (beyond the label)

Institutional review teams often focus on the following, regardless of classification:

Definitions
What exactly counts as “promoting characteristics” or “sustainable investment” in the specific product context?
clarityconsistency
Decision logic
What are the inclusion/exclusion thresholds? How are controversies handled? What triggers escalation?
controlsescalation
Monitoring
What is the monitoring cadence and how are changes recorded and communicated?
cadencetraceability
Reporting
Are disclosures stable across time, and can claims be evidenced without relying on tone?
evidenceauditability

Information that signals seriousness

The strongest signal is the ability to show work: policies, definitions, and a stable process that can be reviewed by a third party.

Practical rule: if a statement cannot be evidenced via documentation or reporting, it should not be presented as a fact.