The EET (European ESG Template) enables ESG-related data transfers from asset managers to distributors, insurers and pension/fund of funds:
1. Suitability assessment required for MiFID II and IDD
2. SFDR disclosure of life-insurance products, through the provision links to the pre-contractual documents (separate single PDF to the prospectus) and periodic documents
3. Client journey for distributors and insurers by filtering information of investor’s sustainability preferences
4. Look-through for SFDR/Taxonomy & TCFD, in order to provide relevant information to fund of funds, pension funds or insurance products for their own disclosure
Suitability assessment and client journey:
The EET includes mandatory information for the suitability assessment, which distributors (MiFID II) and insurers (IDD) need to retrieve per each individual ISIN. On top of this the EET encompasses information to support new client journey/investor profiling options to support the fund selection process in respect to ESG principles, EU Taxonomy alignment, exclusions and PAIs. Hence, it makes sense to include article 6 funds in the EET.
SFDR disclosure
The EET includes links to the fund’s individual pre-contractual documents (PCD) and periodic documents (PD), which are electronic documents separate to the prospectus (annex) or annual report. These documents need to be made available in the relevant local languages otherwise insurers would need to restrict the funds’ scope.
Look-through
The EET encompasses the necessary content of the PCDs and PDs along with the other relevant ESG, SFDR and EU taxonomy disclosures, as well as the UK TCFD to enable the look-through for fund of funds, pension funds or insurance products for their own disclosure.