Question 1 addresses whether changes to the SFDR RTS precontractual templates follow the same regime as any other prospectus amendment, and which changes qualify as "material." The revised answer confirms and refines the CSSF's position on three key points:

• Templates remain part of the prospectus. The SFDR does not impose specific requirements on the review of Article 8/9 precontractual disclosures. Accordingly, ordinary prospectus-amendment rules apply, and all changes must be submitted via the "e-Identification procedure for UCI Prospectus and Offering Document."
• Only material changes require prior CSSF review and authorisation, assessed case-by-case under Circular CSSF 14/591. The updated FAQ sets out a non-exhaustive list of material changes, namely:
  • Material changes to the fund or sub-fund in the context of the ESMA Guidelines on funds' names using ESG or sustainability-related terms (ESMA34-472-440)
  • Changes in the SFDR classification (e.g. a shift between Article 6, 8 or 9)
  • Material changes to the SFDR criteria set-up, including the strategy, index, methodology, investment objective, or a material variation in the threshold.
• Revised materiality framing. The original December 2022 wording centred on minimum committed percentages, binding elements of the investment strategy, and benchmark changes. The July 2026 version replaces that framing with the three categories above, most notably adding explicit references to the ESMA fund-naming Guidelines and to SFDR classification changes as materiality triggers.

• Interaction with the ESMA fund-naming Guidelines. By expressly linking materiality to the ESMA Guidelines (implemented in Luxembourg via Circular CSSF 24/863), the CSSF ties together two previously separate compliance streams, a fund's naming-related self-assessment can itself trigger a material-change process for its prospectus.
• Classification changes are now explicitly flagged. Any planned "upgrade" or "downgrade" of a fund's SFDR status (e.g. moving from Article 8 to Article 6) will require CSSF prior review and, for open-ended UCIs, the one-month investor redemption right under Circular CSSF 14/591.
• Clearer decision framework for routine vs prior-authorisation filings. IFMs, AIFMs and UCITS management companies now have a more concrete, illustrative checklist for determining whether a template change can proceed as a routine filing or requires prior authorisation and possible investor notice.
• Continuity with the "no gold-plating" approach. As with earlier versions, the CSSF is not creating new SFDR obligations but clarifying how existing Circular CSSF 14/591 materiality concepts apply to SFDR-related prospectus changes, reducing interpretive uncertainty for managers preparing prospectus updates.

Although the scope of this update is narrow, a single question, the revised materiality indicators give fund managers a sharper lens through which to assess upcoming template changes. Managers reviewing their Article 8/9 disclosures should revisit their internal change-management procedures to ensure alignment with the updated FAQ, particularly where fund-naming assessments or SFDR reclassifications are under consideration.

The updated CSSF SFDR FAQ (Version 5) can be found here.