This addendum complements the PRI’s February 2026 position paper on the revision of the Sustainable Finance Disclosure Regulation (SFDR).

It provides additional recommendations and practical investor perspectives on a number of issues that have become increasingly prominent in the ongoing Council and European Parliament negotiations and were not addressed in detail in the original paper. The recommendations are informed by further discussions with PRI signatories, exchanges with members of the Global Policy Reference Group (GPRG), and written feedback received since the publication of our initial position paper.

Since the publication of the European Commission’s proposal, negotiations have increasingly focused on the operational design of the new SFDR product categories and the overall scope of the framework. This addendum therefore focuses on four priority areas: the exclusion criteria applicable to the Transition category, the category’s specific eligibility requirements and the scope of application of the regulation.

Drawing on recent investor feedback and developments in the legislative process, the PRI sets out targeted recommendations to support a credible, coherent and workable SFDR framework that provides legal certainty for market participants and supports the effective functioning of sustainable investment markets. 

Download the addendum below.