Real estate investors are finding that the most stringent sustainability classification under EU rules does not fit neatly with their environmental goals. Under the EU’s Sustainable Finance Disclosure Regime, Article 9 – or “dark green” – funds are generally considered the most sustainable. The classification requires a fund to have “sustainable investment as its objective” and is often used an approximation of “impact” investment. The result is that many GPs find that their strategy falls outside the provision. “Of the Article 9 funds we have worked on to date, none are in the real estate sector,” says Justin Cornelius, a partner in the Real Estate group, to New Private Markets. He echoes the common sentiment that, due to the requirements of the article, “You end up in a situation where you’ve got funds that are generating a phenomenal level of environmental improvement, but nevertheless are not achieving that Article 9 classification.”