SFDR Reporting Implementation for Raft Capital

Raft Capital is a leading growth-stage investment firm focused on high-potential companies across the Baltics. The company manages the RAFT CAPITAL Baltic Equity Fund, which raised €50 million from institutional and private investors.

As a financial market participant operating within the European Union, Raft Capital falls under the mandatory requirements of the Sustainable Finance Disclosure Regulation (SFDR). The fund operates as an Article 8 (“light green”) investment product, promoting environmental and social characteristics while integrating ESG considerations into its investment process.

The company already had a foundational ESG framework in place and adhered to Invest Europe standards. However, the organization sought expert support to ensure full compliance with evolving SFDR technical standards and reporting requirements.

Raft Capital undertook to strengthen and formalize its SFDR reporting processes to ensure compliance with Article 8 requirements across both entity-level and product-level disclosures.

The key challenges included:

• Limited portfolio ESG data collection and Principal Adverse Impact (PAI) reporting processes
• The evolving complexity of the latest SFDR technical standards created a need for clearer processes
• Missing or incomplete disclosure templates aligned with Annex II and Annex IV requirements
• Need for improved integration of sustainability risks into policies and reporting frameworks
• Tight implementation timelines for the upcoming regulatory reporting cycle

The project also required balancing regulatory compliance with practical implementation, ensuring that the reporting process remained scalable and proportionate to the fund’s operational maturity.

Civitta designed a structured SFDR implementation roadmap tailored to Raft Capital’s operational model and reporting maturity level. The approach focused on achieving regulatory compliance efficiently while creating a foundation for future ESG development.

• Gap Analysis & Regulatory Assessment

The project began with a comprehensive assessment of Raft Capital’s existing ESG policies, disclosures and reporting processes against SFDR requirements, covering sustainability risk policies, remuneration policies, existing ESG disclosures and current reporting practices. The analysis identified compliance gaps across PAI statements, pre-contractual and periodic disclosures (Annex II and IV), Article 10 website disclosures, and ESG governance and monitoring processes.

• SFDR Disclosure Development

Building on the gap analysis, Civitta prepared the full set of required SFDR disclosures and reporting templates: Article 3 sustainability risk disclosures, Article 5 remuneration policy disclosures, a PAI “explain” statement under Article 4, Annex II and IV templates, and Article 10 website disclosure content. Particular attention was given to developing a compliant “comply or explain” approach for Principal Adverse Impacts, ensuring transparency while acknowledging current data limitations for certain asset classes.

• Governance & Stakeholder Alignment

Civitta established a clear implementation structure covering roles and responsibilities, internal governance processes, review and approval workflows, data collection and validation requirements, and reporting timelines and milestones.

The project also included working sessions and knowledge transfer activities to improve the client team’s understanding of SFDR obligations and long-term ESG reporting expectations.

The project provided Raft Capital with a clear and structured pathway toward SFDR compliance for the upcoming reporting cycle.

Key outcomes included:

• Development of SFDR-compliant entity-level and product-level disclosures
• Creation of standardized Annex II and Annex IV reporting templates
• Preparation of Article 10 website disclosure content
• Formalization of the PAI “explain” approach
• Improved alignment between ESG policies and regulatory obligations
  

Beyond compliance, the engagement strengthened Raft Capital’s internal understanding of SFDR requirements, reduced regulatory and reputational risk, and improved ESG governance and reporting consistency. It also enhanced transparency with investors and put in place a scalable ESG reporting framework that the team can build on going forward.

By the end of the project, Raft Capital had established a repeatable and practical SFDR reporting process aligned with current EU sustainability finance regulations.

Civitta’s expertise in sustainability regulations, ESG reporting, and financial sector advisory enabled Raft Capital to strengthen compliance while laying the groundwork for more advanced ESG integration in the future.

The project highlighted the importance of translating complex sustainability regulations into practical and manageable reporting processes for investment firms.

Key lessons learned:

• Effective SFDR implementation requires strong coordination between compliance, investment, and reporting teams
• Practicality and scalability are essential when developing ESG reporting frameworks for mid-sized investment organizations
• Even limited ESG data environments can achieve compliance through transparent methodologies and structured disclosure approaches
• Early governance alignment significantly reduces implementation complexity and reporting risks