In January 2023, the Sustainable Finance Disclosure Regulation (SFDR) Level 2 took full effect, marking a significant milestone in the landscape of sustainable finance in Europe and across the world. As the financial industry adapted to this regulatory shift, the infrastructure sector found itself at a crucial juncture, grappling with the task of aligning with the disclosure requirements mandated by SFDR. Nearly a year later, having crossed the critical deadlines set by the new regulation — the SFDR data on Principal Adverse Impact (PAI) ESG metrics was due by June 30 — we can now embark on a retrospective analysis and examine the sector’s readiness and compliance levels by looking at GRESB Benchmarking data, GRESB SFDR participation data, as well as the market’s public disclosure on this specific legislation.

Using the GRESB Infrastructure Benchmark as a proxy for the sector, we analyzed how infrastructure assets reported on ESG metrics in line with SFDR, focusing ou