The rules ask you to put version history in a file name.
Kilospring is a publication register for investment firms. SFDR's technical standards ask that a downloadable disclosure carry its version history in the name of the file, because a file name is the only place there is to put it. An address with the history behind it answers the same question once, and keeps answering it.
- IFR Article 46
A firm outside the small and non-interconnected category discloses on the same date as it publishes its annual financial statements. It chooses the medium and location itself; where the same or similar information sits in more than one, each carries a reference to the others.
- IFR Articles 47 to 52
Risk management, governance, own funds and remuneration are disclosed with the accounts. Investment policy applies above the threshold in Article 32(4) of the accompanying directive.
- IFR Article 53
Environmental, social and governance risks are disclosed once in the first year and half-yearly after that — the one item in the set that does not follow the annual cycle.
- SFDR Article 12
What is published under Articles 3, 5 and 10 is kept up to date, and where it is amended, a clear explanation of the amendment is published on the same website.
- SFDR RTS Article 2
The date of publication and the date of any update are stated. Where the information is a downloadable file, the version history is indicated in the file name.
We do not read any of this for you, and we take no view on whether you have met it. Note that IFR lets you choose the medium and the location yourself — what it asks is that the disclosures sit together, and that where they appear twice, each points at the other.
What hangs where
The firm, and what it manages for someone else.
A document is attached to the firm or to a portfolio it manages or advises on. The attachment decides where the document is shown; it does not decide the address.
The firm. Published in your own name, and read long after the day it went up.
/d/example-capital-sustainability-risk-policy-en- Prudential disclosureswith the accounts
- Environmental, social and governance riskshalf-yearly
- Sustainability risk policySFDR Article 3
- RemunerationIFR Article 51 · SFDR Article 5
- Statement on principal adverse impactswhere you make one
- Complaints handling and its formper language
A portfolio or mandate. What is published for what you manage or advise on, and referenced from the documents that describe it.
/d/example-capital-strategy-sustainability-en- Sustainability-related disclosuresSFDR Article 10
- Pre-contractual annexesone per language
Where the address ends up
One location, and the references to it.
Every one of these is a place an address is written down and then left alone. The document behind it changes on its own schedule; the address does not have to.
- The other medium
Where the same information appears in more than one place, each place carries a reference to the other. Those references are addresses, and they are written once.
- The file name
The rules ask for the version history to be written into the name of a downloadable file. An address that carries the history instead is the same answer, given once.
- Pre-contractual documents
They point at the website for what is disclosed there, and they are printed, circulated and kept.
- Client agreements and terms
Which version a client agreed to is a question that gets asked years later.
- Your annual report and your filings
Published on a date, referring to information that keeps changing after that date.
Scope
A register, not a place to keep policies.
The line matters more here than anywhere else, because the documents look like the ones a policy tool holds. It is the same line as everywhere else in the register: the document already exists, and we keep the record of its publication.
Drafting, review cycles, approval routing, review dates, staff attestations and mapping to a rulebook are policy management. That is a mature category with capable suppliers, bought by a different person for a different reason. We begin where it ends: an approved document, ready to be published.
The internal version of a policy — the one with tracked changes and the approval date — is none of our business. What we hold is the version you published, the day it took effect, the day it stopped applying, and the file itself, byte for byte.
Not drafting, reviewing or approving a document
Not deciding whether a review is due, or when one is
Not collecting attestations from your staff
Not mapping a document to a rule or an obligation
Not an intranet, and not a place your staff log in to read
Getting started
Start with the page you point people at today.
Most firms have one: a page of links, added to over the years, where the disclosures live. A good first step is that page — the documents on it as they stand, the earlier versions where you still have them, and the dates they took effect. How the setup runs, what the register records and where our responsibility ends is written out on the front page.