The E.U. Sustainable Finance Disclosure Regulations (SFDR) set forth a disclosure framework for funds based on whether and how they seek to engage in sustainable investing or consider environmental, social and governance factors in the investment process. Since the SFDR took effect in 2021, the number of funds launched that satisfy its requirements has continued to grow each year. On November 20, 2025, the European Commission issued a proposal to substantially revise the SFDR (Proposal). If adopted, the Proposal would eliminate certain entity-level requirements; replace the current Article 9 approach, which is tied to the definition of “sustainable investment,” with exclusion-based criteria; add a new category for funds with transition-related objectives; and make other product-level changes. A recent Linklaters program examined the key elements of the Proposal, which the speakers referred to as “SFDR 2.0,” and how it would change the existing SFDR regime. The program featured Linklaters partner Raza Naeem, managing associate Clare Wiles and counsel Julia Vergauwen. This article parses their insights and the relevant provisions of the Proposal, including key differences between the Proposal and an earlier, leaked version. See “SFDR Impact Analysis Finds Sustained Growth in E.U. Sustainability‑Focused Funds, Despite U.S. Headwinds” (Jun. 12, 2025).