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Better Finance found that 57% of the 2332 UCITs funds it was able to investigate using the ESMA sampling criteria escape scrutiny because of a lack of available information. Of those it was able to investigate, 16 % (165 funds in total) displayed characteristics that flag them as potential closet index funds based on the ESMA metrics.

Read the full press release here.


In order to replicate the ESMA study as closely as possible, Better Finance also used the Morningstar database and filtered the full universe of funds using the same criteria as ESMA, both explicit and implicit.

In order to faithfully present the findings of the study, the same criteria and time period were used as those by ESMA. Better Finance also analysed the funds that ESMA excluded from its analysis because it could not retrieve the necessary data.

Read the full methodology here.


Our additional review of investor disclosure documents revealed that many of the funds with the highest potential of being closet indexers according to ESMA do not disclose their benchmark’s performance alongside their own performance in their KIID although they do disclose a benchmark in their prospectus.

Read more about our additional findings here.