ESG
On 24 August 2026, ESMA published its compliance table on the Guidelines on Enforcement of Sustainability Information (GLESI), providing a consolidated overview of national enforcers’ adherence to the GLESI across the EU and EEA. ESMA has noted that the first years of application of the ESRS involve a learning curve for all parties, requiring an adjustment period, and that application of the GLESI will therefore need to be proportionate and realistic. NCAs retain built-in flexibilities to adapt their supervisory approach, including through dialogue and informal measures, while reserving enforcement actions for cases where necessary.
The compliance table reveals a mixed picture across Member States: while a majority of NCAs fully comply or intend to comply, several others do not yet comply, citing legislative gaps, resource constraints or ongoing transposition processes. In Luxembourg, the CSSF has indicated that it intends to comply with the GLESI by such time as the CSRD has been transposed into national legislation.
ESMA continues to monitor the Omnibus legislative process and its impact on sustainability reporting and enforcement, including the "stop-the-clock" mechanism postponing CSRD/ESRS obligations for wave 2 and wave 3 companies and the Omnibus 1 Directive, which must be transposed by Member States by 19 March 2027. Fund managers and sponsors with listed issuers in their portfolio structures should take note of the varying levels of supervisory readiness across jurisdictions, particularly for cross-border groups subject to enforcement in multiple Member States.
The CSSF has drawn market participants' attention to the fact that Regulation (EU) 2024/3005 on the transparency and integrity of ESG rating activities (the ESG Ratings Regulation) started applying on 2 July 2026.
The ESG Ratings Regulation introduces a new disclosure obligation under Article 49, amending Article 13 of the SFDR: financial market participants and financial advisers within scope of the SFDR that issue or disclose an ESG rating to third parties as part of their marketing communications must include on their website the information required under point 1 of Annex III of the ESG Ratings Regulation, i.e. the minimum disclosures to the public, and must include a link to those website disclosures in the marketing communications concerned. The CSSF expects compliance with these obligations as from 2 July 2026.
The CSSF has also highlighted an ESMA public statement clarifying that, between 2 July 2026 and 2 November 2026, third parties may continue to publish or distribute ESG ratings issued by existing but not-yet-authorised ESG rating providers that have notified ESMA of their intention to continue operating in the Union, pending ESMA's decision on their authorisation, recognition or registration.
The CSSF has confirmed it will continue to monitor regulatory developments regarding the SFDR and will apply a proportionate approach in its supervisory practices in light of remaining uncertainties and the evolving regulatory landscape.
On 21 July 2026, the CSSF published the fifth version of its FAQ on the SFDR, modifying the answer to the question relating to the material nature of the changes made to the SFDR RTS precontractual templates under Articles 8 and 9 SFDR.
The updated guidance confirms that where the SFDR RTS templates are included in a fund's prospectus or issuing document, they form an integral part of that document and any change to them must follow the same regime as any other prospectus/issuing document change, via the e-Identification procedure for UCI Prospectuses and Offering Documents. Only material changes to the templates — as assessed on a case-by-case basis under Circular CSSF 14/591 — require prior CSSF review and authorisation. The CSSF lists non-exhaustive examples of material changes, including changes relevant to the ESMA Guidelines on funds' names using ESG or sustainability-related terms, changes in SFDR classification, and material changes to the SFDR criteria (strategy, index, methodology, investment objective, or material variation of a threshold).
On 23 September 2026, the CSSF alerted market participants to the fact that the ECGT Directive, transposed into Luxembourg law by the Law of 9 June 2026 amending the Consumer Code, would apply from 27 September 2026. The ECGT Directive introduces new requirements in relation to sustainability-related consumer-facing communications. The CSSF expects financial market participants to ensure that consumer-facing sustainability-related claims are clear, accurate and duly substantiated, and that requirements imposed by law are not presented as a distinctive sustainability feature.