
From PDF to JSON: Converting your SFDR annexes for CSSF filing
This article provides a comprehensive guide for fund managers navigating the shift from PDF to JSON for SFDR Annexes, driven by CSSF's updated filing requirements. By following our step-by-step instructions, you can ensure full compliance, optimise your regulatory processes, and mitigate compliance errors in your filings.
With the CSSF’s mandate for digital SFDR submissions in JSON format, Luxembourg fund managers can no longer rely solely on traditional PDF disclosures. Instead, they must translate the familiar Annex II, III, IV, V templates into structured, machine-readable JSON files — a process that requires both strategic planning and technical precision.
This article walks you through how to convert your SFDR Annexes from PDF to JSON, ensuring full alignment with CSSF filing requirements and avoiding compliance headaches.
Why move from PDF to JSON?
PDFs are designed for human readability. JSON files are designed for automation, comparison, and regulatory parsing. The CSSF eDesk portal now requires both formats, with JSON being essential for:
- Structured validation
- Regulatory supervision
- Data standardisation across Article 8/9 funds
PDF vs. JSON: What's the difference?
Step-by-Step Guide: Converting SFDR Annexes to JSON
Step 1: Extract and structure your ESG data
Before converting, ensure all Annex content is centralised and structured.
- Sustainability objectives
- E&S Characteristics
- Principal Adverse Impacts (PAIs)
- Taxonomy alignment data
- Asset allocation data
- Activities investment share data
- Top 15 holdings
- Narratives where data is unavailable

- Manual coding (not recommended for scale):
a. Requires knowledge of JSON structure and CSSF schema
b. Risk of syntax or structural errors
2. Vendor tools / RegTech platforms:
a. Platforms such as FE fundinfo's Nexus automated conversion tools
b. Ideal for handling large product inventories
3. In-house automation scripts
a. Using Excel-to-JSON macros or Python-based generators
b. Can be templated once mappings are stable
- Required fields present
- Correct data types (e.g., string, number, boolean)
- Logical consistency (e.g., proportion totals = 100%)
- Correct file format and encoding (UTF-8)
- Use a schema validator (online tools or internal tools aligned to CSSF specs).
- Test with sample submissions before bulk uploads and update based on the CSSF’s feedback file.
- File naming conventions follow CSSF guidelines
- You log the submission time and reference for audit purposes
- You retain the source data for future corrections or re-filings
Best Practices for a smooth conversion

- An internal reporting hub for ESG data
- Ongoing monitoring of CSSF schema changes
- Staff training or documentation for JSON workflows