The qualifying criteria for labels were designed to accommodate both active and passive strategies, where for passive strategies the product tracks an index that meets the criteria for a label.
To meet the criteria for a label, a fund manager must ensure that at least 70% of the gross value of the sustainability products' assets are invested in accordance with the sustainability objective. This doesn’t necessarily mean that the sustainability objective is pursued on an asset-by-asset basis, provided that at least 70% of the gross value of the products' assets are invested in accordance with the sustainability objective.
In the policy statement and final criteria, we clarified that KPIs to demonstrate progress towards the sustainability objective can be either product-wide or asset-specific. Managers will need to determine which KPIs are appropriate for their fund. For example, for index-tracking strategies, product-wide KPIs may be preferred where they align with portfolio selection and monitoring processes.
Managers must be able to demonstrate that 70% of the gross value of assets held within the fund are invested in accordance with the sustainability objective on an ongoing basis. In the policy statement, we acknowledged that assets may be removed or added when an index provider rebalances the index. However, the fund manager retains responsibility for meeting the criteria. Where the fund is judged to no longer be invested in accordance with the sustainability objective, the manager must take steps to restore compliance with the criteria as soon as reasonably practicable.
We haven’t prescribed monitoring processes to ensure that the criteria are met. We noted, for example, that for index funds this may include regular engagement with the index provider. Managers must monitor their funds as appropriate and meet the relevant disclosure requirements.
We acknowledge that stewardship may take place in different forms for different asset classes and strategies. Stewardship can be undertaken at the overall firm-level or on a product-specific basis. Managers must ensure that the investor stewardship strategy and appropriate resources are applied to support the achievement of the sustainability objective, including with respect to index-tracking strategies.
Products tracking Paris-Aligned Benchmarks and Climate Transition Benchmarks can qualify for labels, provided that the qualifying criteria are met. But tracking those benchmarks alone doesn’t necessarily mean they meet the criteria for a label. As with all labels, firms will need to determine whether the fund meets the criteria.