Los fondos artículo 9 “Dark Green” are still marginal (0.6%) in Spain, despite the rise of sustainable investment

Only 0.6% of ESG investment in Spain corresponds to Article 9 funds—the products with the highest level of social and environmental impact ambition—according to the second edition of the report The Challenges of Sustainable “Dark Green” Investment 2025 in Spain, presented today in Madrid by the UPF Barcelona School of Management (UPF-BSM), Gabeiras, and Triodos Bank. The study warns that although sustainable investment has surged in recent years, growth has been largely concentrated in Article 8 products, which entail lower requirements and a more limited sustainability impact.

As of June 2025, assets invested in sustainable financial products in Spain amount to €159.504 billion, representing 38% of the total market. However, Article 9 funds—specifically designed to generate measurable positive impact—barely reach €2.582 billion, an almost negligible figure within the ESG universe.

The report provides a detailed analysis of the sustainability of the portfolios of the 17 Spanish UCITS investment funds classified as Article 9 or “Dark Green” under the Sustainable Finance Disclosure Regulation (SFDR), highlighting several structural challenges: limited transformative ambition, lack of homogeneity in sustainability criteria, the risk of greenwashing, and the absence of clear standards to guarantee the real impact of investments.

According to Marcos Eguiguren, “These figures clearly show that despite the ESG investment boom in Spain, funds genuinely focused on sustainability objectives (Article 9) have not taken off to the same extent. Asset managers have largely opted to classify their products under the umbrella of Article 8,” emphasized the Director of the International Chair in Sustainable Finance at UPF-BSM and Triodos Bank.

For her part, Susana Cabada, Director of Personal Banking at Triodos Spain, stated: “To accelerate the ecological and social transition, it would be desirable to encourage the launch of more Article 9 funds, perhaps through greater regulatory clarity and educational efforts so that asset managers feel more confident in this category.”

Greenwashing and lack of homogeneity

The study warns that many retail investors do not clearly distinguish between the different levels of sustainability among financial products. This stems from “information asymmetry and the complexity of the regulatory framework, rather than an intention to mislead on the part of asset managers. However, the risk persists that a client may invest in a fund believing it to be more sustainable than it actually is,” noted Oscar Elvira, co-author of the study and professor at UPF-BSM. The report highlights that the solution lies in greater transparency and financial education in this area.

Furthermore, the analysis reveals a lack of homogeneity in the sustainability indicators of Article 9 funds, making product comparability difficult. “To strengthen market credibility, it would be highly advisable to move toward common standards or benchmark ranges for these indicators—something that SFDR 2 is currently working on,” Elvira added.

Although ESG rating agencies tend to agree in their assessment of risks, the report recalls that these ratings primarily measure financial risks and not the real impact of companies on the social and environmental environment.

The report also reveals that portfolios are reducing their exposure to investments with high ESG risks, making this a determining factor in the investment decisions of Article 9 fund managers.

Article 9 does not guarantee sustainability

The report also concludes that the Article 9 SFDR category does not equate to a guaranteed green label. “SFDR establishes disclosure obligations but does not define minimum quantitative standards, nor is it effectively creating a homogeneous and transparent ‘label’ in practice,” explained Patricia Gabeiras, founding partner of Gabeiras and co-author of the study.

In fact, the analysis shows that the proportion of Article 9 fund portfolios aligned with the objectives of the Paris Agreement—to limit global warming to below 2ºC—has decreased from 72.4% in 2022 to 63.6% in 2024.

Exposure to less sustainable sectors

The study warns that some Article 9 funds were found to have exposure to less sustainable industries such as tobacco, arms, or oil. Although 89.9% of these funds’ portfolios are involved in non-controversial sectors, the study identified 9.6% invested in controversial sectors.

Among its conclusions, the report also highlights that Article 9 fund managers refer at some point to the United Nations Sustainable Development Goals (SDGs) as frameworks for their investments, but in most cases these references are “generic, imprecise, and difficult to measure.”

An event to promote sustainable finance

The report presentation event, held at the Harmon space in Madrid, was chaired by Marcos Eguiguren, Director of the International Chair in Sustainable Finance at UPF-BSM, and Susana Cabada, Director of Personal Banking at Triodos Spain. It also featured contributions from the study’s authors: Oscar Elvira, professor at UPF-BSM; and Patricia Gabeiras, founding partner of Gabeiras.

The event included a roundtable discussion with Pablo Esteban, Deputy Director General of Spainsif; Antonio Ortiz, Deputy Director for Sustainable and Digital Finance at Spain’s Ministry of Economic Affairs and Digital Transformation; Begoña López, Deputy Director of the Department of Strategy, Innovation and Sustainable Finance at the CNMV; and Claudia Antuña, partner at AFI.

Antonio Ortiz outlined the lines of work being deployed within the framework of the Sustainable Finance Council to promote sustainable financing. Ortiz emphasized that last week Eco-Track was presented to the Council—a tool enabling SMEs to easily provide sustainability information. “This measure will help companies identify investment opportunities and financial institutions manage their loan portfolios more efficiently, ultimately contributing to mobilizing financing,” said Ortiz. He also highlighted the revision of the SFDR regulation, which will reorient the rule toward a “genuinely product-based regulatory instrument” expected to bring clarity, coherence, and simplification to the European sustainable finance framework.

Begoña López stressed that “as concluded in the joint supervisory action carried out at the European level in 2025, sustainability information remains, in many cases, too vague.” For López, “It is essential that sustainability claims are fair, clear, and not misleading, that they are substantiated and consistent with portfolios. Therefore, combating greenwashing and improving transparency are global priorities where we must continue to focus our efforts. We also welcome the revision of SFDR and support simplification, without losing sight of the regulation’s objectives.”

Pablo Esteban explained that “there is understandable caution on the part of asset managers for reputational and regulatory reasons. ESG metrics are complex, and the market reflects a strong concentration in banking and utilities due to risk-reduction policies. Therefore, advancing interoperability is key—especially with distribution rules and regulations that ensure accessibility and availability of reliable sustainability data. It will also be very important to clarify the calculation methodology to reach specific thresholds for each category and to assess whether these labels are truly understandable for investors.”

Finally, Claudia Antuña concluded: “The predominance of fixed income responds to market supply and to the fact that it allows for better identification of sustainable investment and its traceability. The new proposal to revise SFDR could improve client understanding, although its impact on demand remains uncertain. Therefore, asset managers’ preparation and strategic anticipation will be key, enabling them to design a strategy that is sufficiently robust yet flexible enough to adapt to these changes.”