Almost two years after the European Union's Sustainable Finance Disclosure Regulation came into force in March 2021, the landscape of funds classified as "light green" (Article 8) or "dark green" (Article 9) is going through some radical changes. In recent months, asset managers have been preparing to implement the SFDR Level 2's regulatory technical standards, or RTS, which came into effect in January 2023 and require managers to disclose more information on their funds' environmental, social, and governance approaches, sustainability risks, and impact in precontractual documents and periodic reports.

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The EU Ecolabel is an EU-wide label awarded to green products and services. A version of the label for retail financial products has been considered as an option to help retail investors make informed investment decision on the sustainability features of investment products. In this article we test three key Ecolabel criteria on a sample of 3 000 sustainability-oriented UCITS equity funds with EUR 1 trillion in assets under management. Using fund portfolio holdings and proxy data, we find that only 16 funds (0.5 % of our sample) meet the proposed minimum portfolio greenness threshold of 50 % and exclusion requirements. These findings highlight the trade-off between the stringency and feasibility of the Ecolabel requirements. The article further illustrates the impact of different threshold calibrations on the number of eligible funds and potential volumes of green finance channelled through Ecolabel funds. The analysis does not prejudge any policy developments or decisions regarding an EU Ecolabel for financial products.