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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.

Focus areas:
  • 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
Create a spreadsheet or database to organize this information in line with RTS field requirements.
Step 2: Map Annex content to JSON fields
Use the CSSF JSON schema documentation to map each section of Annex II/V to its corresponding JSON key.
Example mapping:
You’ll likely need a field dictionary or mapping file to track transformations across formats.
Step 3: Choose your conversion method
There are three primary methods to generate the JSON:
  1. 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 

Step 4: Validate your JSON file
Every JSON file must pass the CSSF’s technical validation schema before submission. This checks for:
  • 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)
Validation tips:
  • 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.
Step 5: Submit via CSSF eDesk
Once validated, submit the JSON file through the CSSF eDesk platform along with the PDF Annex.
Ensure:
  • 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
FE fundinfo can can complete both the creation and filing to the CSSF via e-file.

Best Practices for a smooth conversion

Scaling your reporting process
For firms with multiple funds or frequent updates, this process should become repeatable and scalable. Consider investing in:
  • An internal reporting hub for ESG data
  • Ongoing monitoring of CSSF schema changes
  • Staff training or documentation for JSON workflows

Conclusion

Converting SFDR Annexes from PDF to JSON is no longer just a technical task — it’s a core compliance function. By understanding the data structure, planning your mappings, and validating early, asset managers can meet CSSF requirements confidently and efficiently.