The definitions and guidance in regulations provide room for interpretation but also pose challenges such as interpreting the minimum standards and its fragmentation across different regulatory regimes.

It is crucial to document the rationale and thought process followed by the asset manager to ensure transparency and allow for auditing.

Asset managers should implement appropriate governance, including documentation of methodologies and related processes, with a central committee to help in oversight. This also involves training and disseminating information to stakeholders involved in labeled products, ensuring they understand and comply with regulatory requirements and internal minimum standards.

Wherever possible, consider the feasibility of maintaining a common base to support consistency across interpretations.

When such consistency is not possible, a clear understanding and documentation of differences and commonalities is needed.

Allowing flexibility at the outset provides room for the evolution of definitions as standards and data landscapes change.

After establishing governance, focus on anticipating upcoming changes and preparing for them, through the dedicated committee’s expertise.