Joint letter asks European Commission to delay technical changes by supervisors until broader review of SFDR is complete
Joint letter asks European Commission to delay technical changes by supervisors until broader review of SFDR is complete
In a joint letter, EFAMA, together with the European Banking Federation (EBF), Insurance Europe, European Savings and Retail Banking Group (ESBG), Alternative Investment Management Association (AIMA), Association for Financial Markets in Europe (AFME), and the European Association of Cooperative Banks, have released a joint letter asking the European Commission to better coordinate the publication of new rules for the Sustainable Finance Disclosure Regulation (SFDR).
In our latest Monthly Statistical Release, we show the following main developments in November 2023 for the investment fund market:
New report calls for action to be taken to revive the Capital Markets Union project
This report analyses the progress made in recent years by European households in allocating more of their financial wealth to capital market instruments (pension plans, life insurance, investment funds, debt securities and listed shares) and less in cash and bank deposits. It also includes policy recommendations on improving retail participation in capital markets, including for the Retail Investment Strategy currently under discussion.
Some key findings include:
However, European supervisors’ proposed technical standards threaten the success of the new regime
Today’s European Parliament vote concludes the MiFID/R review process
IZFiA (Izba Zarzadzajacych Funduszami i Aktywami) has just joined EFAMA, the Brussels-based trade body representing the European investment management industry.
In its support of the development and implementation of the Taxonomy Regulation, EFAMA believes that reporting on the level of alignment with the Taxonomy by non-financial and financial undertakings is essential to strengthening market integrity around sustainability issues.
FIA, ISDA, AFME, ICI, AIMA, EBF and EFAMA (together the Associations) welcome the
European Commission's (the Commission) timely and temporary equivalence decision from
21 September 2020 with respect to UK central counterparties (CCPs) and subsequent
recognition decisions by ESMA of CCPs and the recent temporary equivalence decision for
UK Central Securities Depositories (CSDs) under CSDR. Together, these steps have provided
much needed certainty for continued and uninterrupted access to these CCPs and CSDs by
EFAMA has some concerns with ESMA’s clarifications. In the consultation paper (CP), ESMA seems to have a very broad interpretation of the ‘multilateral systems’ definition under MiFID II and states that ‘systems where trading interests can interact but where the execution of transactions is formally undertaken outside the system still qualify as a multilateral system and should be required to seek authorisation’ (paragraph 36).
We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as:
Article 51(5) of the BMR provides that, unless the Commission has adopted an equivalence decision in relation to a particular third country, a third country administrator has been recognised or a third country benchmark has been endorsed, EU supervised entities may only use a third country benchmark in financial instruments, financial contracts and measurements of the performance of an investment fund that already reference the relevant benchmark prior to 31 December 2021.
EFAMA is grateful for the opportunity to comment on some messages included in the aforementioned roadmap. We believe that these comments should be made clear for all persons interested, especially to those who would like to participate in the upcoming public consultation.

Discover the 6 reasons why your organisation should become a member of EFAMA.
Our members enjoy significant benefits including the opportunity to shape the industry positions, get first-hand access to regulatory and political intelligence, engage with industry peers and policymakers, and take part in EFAMA events.
Our three membership categories cater to the wide range of organisations that make up and support the investment management industry in Europe.