What is the difference between an Article 8 and an Article 9 fund for the company it invests in?

An Article 8 fund promotes environmental or social traits and checks that you follow good governance. An Article 9 fund must treat almost every holding as a sustainable investment, so it has to show your company contributes to an environmental or social goal, does no significant harm and is well governed. Expect deeper diligence from Article 9.

What each fund must prove about you

• Article 8: that you meet the environmental or social characteristics the fund promotes, often exclusions or minimum ESG scores, and that you follow good governance practices.
• Article 8 with a sustainable investment share: the same, plus the full sustainable investment test for the part of the fund it counts as sustainable.
• Article 9: the full test for nearly every holding, apart from cash and hedging. A fund whose objective is cutting carbon is expected to track an EU Climate Transition or Paris-aligned Benchmark where one exists.

The sustainable investment test in Article 2(17)

SFDR does not fix how a fund measures contribution. The Commission's answers published in April 2023 confirm each fund sets and discloses its own method, so two Article 9 funds can judge the same company differently.

1. Contribution: your activity contributes to an environmental or social objective, measured by indicators such as emissions, energy, water or revenue from climate solutions.
2. Do no significant harm: you do not seriously harm other objectives. Funds apply this using the PAI indicators, so your emissions, fossil exposure, waste and controversies are checked.
3. Good governance: sound management structures, employee relations, staff pay and tax compliance.

What changes for you in practice

• Data: an Article 9 fund needs your PAI figures to clear the harm test, not just to report them.
• Ongoing checks: if you fail the test later, an Article 9 fund may have to sell or stop counting you as sustainable. An Article 8 fund usually has more room.
• Evidence: claims about climate contribution need numbers with sources, such as tonnes avoided or revenue share, not descriptions.

A pending change to the labels

The Commission proposed on 20 November 2025 to replace the Article 8 and 9 labels with three product categories: sustainable, transition and ESG basics. The Council agreed its position on 24 June 2026, and talks with the Parliament were being prepared in October 2026. Until a final text is agreed and applies, Articles 8 and 9 remain the law, and funds will keep asking for the same data.

What Senseible does here

Senseible keeps the evidence behind the environmental figures a fund cites, such as emissions and energy use from your invoices and bills, as a self-declared record. It does not assess whether a fund or your company qualifies under Article 8 or 9.

• Why EU funds ask for SFDR PAI data
• SFDR PAI data request: what to send
• EU Taxonomy DNSH criteria explained

Sources: Regulation (EU) 2019/2088 on sustainability-related disclosures (SFDR), Articles 2(17), 4, 8 and 9 (eur-lex.europa.eu), Commission Delegated Regulation (EU) 2022/1288, Annex I (eur-lex.europa.eu), European Commission answers on SFDR questions (April 2023), in the ESAs' consolidated questions and answers on SFDR (JC 2023 18), European Commission, proposal to revise SFDR (20 November 2025)

Last reviewed 2026-10-17. SFDR revision trilogues were being prepared in October 2026; check whether the Article 8 and 9 labels have been replaced before relying on this page.