What is the difference between Article 6, 8, and 9?

Article 6 products do not promote sustainability characteristics and only disclose how sustainability risks are integrated. Article 8 ('light green') products promote environmental or social characteristics. Article 9 ('dark green') products have sustainable investment as their explicit objective. The bar rises from disclosure-only to active promotion to a sustainability mandate.

Does an Article 9 fund have to be 100% sustainable investments?

In practice, yes. Following ESMA and Commission Q&A guidance, an Article 9 product is expected to invest only in sustainable investments, aside from cash held for liquidity and assets used for hedging. Anything materially below that points to Article 8 rather than Article 9.

What does 'do no significant harm' (DNSH) mean here?

DNSH requires that an investment counted as 'sustainable' does not significantly harm any other environmental or social objective, assessed using mandatory PAI indicators. Both Article 8 (for its sustainable sleeve) and Article 9 products must apply the DNSH test to those investments.

Whether you consider principal adverse impacts at product level is a disclosure choice, but it strongly signals classification. Article 9 and most credible Article 8 products consider PAIs. Large managers (over 500 staff) must also report PAIs at entity level on a comply-or-explain basis.

Is this classification legally binding?

No. SFDR classification is the manager's own responsibility and must be substantiated in pre-contractual and periodic disclosures and reflected accurately in the prospectus. This tool is an informational triage aid only; confirm with legal and compliance before labelling any product.

SFDR Product Classification Checker

The EU Sustainable Finance Disclosure Regulation (SFDR) sorts financial products into three disclosure regimes. Getting the article right matters for marketing, template disclosures, and greenwashing risk. This checker applies the core decision logic so you can triage a product before formal classification.

How it works

The logic follows the regulation’s structure from the top down:

1. Sustainable investment is the objective?            -> Article 9
   (expects ~100% sustainable investments + DNSH + governance)
2. Promotes E/S characteristics (and applies DNSH to
   any sustainable sleeve)?                             -> Article 8
3. Neither — only integrates sustainability risk?       -> Article 6

An Article 9 claim is downgraded to Article 8 if the minimum sustainable-investment share is materially below 100% or DNSH/governance safeguards are missing, because the “dark green” bar is the strictest in the regime.

Notes and example

A global equity fund that screens out controversial sectors, tilts toward high-ESG-score issuers, targets 30% sustainable investments, applies DNSH and considers PAIs is a textbook Article 8 product. Relabel its objective as “sustainable investment” but keep only 30% in sustainable assets and the tool flags that it cannot credibly be Article 9 and should stay Article 8. Always substantiate the final choice in the pre-contractual and periodic SFDR templates.