Our associations are committed to supporting the transition to a more sustainable economy and 
to tackling climate change that we consider a priority. We strongly support the EU objective of 
transforming Europe into the first climate-neutral continent in the world by 2050 and are ready 
to contribute as representatives of the financial sector. 

With this letter, we would like to address a project that we consider particularly important: the 
creation of a centralized electronic register for Environmental, Social and Governance 
(ESG) data in the EU.

The recent regulatory developments in the context of the EU Sustainable Finance agenda create 
an urgent need for publicly available ESG data as well as how to enhance their sourcing.
Compliance with the new disclosure obligations introduced by the sustainability disclosures
Regulation(SFDR) requires financial market participants to have access to comparable robust 
and reliable ESG data at the level of companies. From the perspective of the EU taxonomy 
Regulation, companies subject to the NFRD (non-financial reporting directive) will have to 
disclose how and to what extent their activities qualify as environmentally sustainable as defined 
in the Regulation. 

Robust, comparable and reliable ESG data is also key to identify and assess sustainability 
risks in lending activities. In addition, availability of ESG data is also necessary to enable financial 
institutions and investors to steer their portfolios towards the objectives of the Paris Agreement 
and of the European Green Deal much more efficiently and on a much broader scale. 
Unfortunately, the availability of quality, comparable, reliable and public ESG data is 
currently rather limited and insufficient to comply with the increasing expectations and 
new regulatory requirements due to apply shortly. When available, data is often difficult to 
compare and raises reliability questions. Moreover, ESG data by third party providers is often
expensive in particular for small-size financial market players, researchers or academia. With an 
increasing demand for ESG information, the fragmentation in ESG third party data providers risks 
to lead to insufficient availability of comparable and reliable ESG data as well as to unnecessary 
costs and competition concerns.

Therefore, ensuring availability of high quality and comparable ESG data should be regarded as 
an EU strategic infrastructure project to meet the EU sustainability objectives both under the 
Action Plan on Sustainable Finance and the EU Green Deal. 

For this reason, we call the EU to build and / or support, based on existing solutions, a 
centralised electronic European ESG data register. We understand that a common European 
Green Deal dataspace to support the Green Deal priorities is already envisaged in the EU data 
strategy. We encourage the European Commission to investigate how our proposal can fit in this 
context.

As a first building block, the European data register should focus on ESG disclosure in line with 
NFRD, EU taxonomy based information, starting with climate change adaptation and 
mitigation objectives, as well as ESG data necessary to financial market participants to 
comply with the SFDR.

As another building block the register should include relevant ESG information already 
collected by European and national institutions such as governments, central banks, 
statistical bodies, etc. Member States are already reporting environmental expenditures under 
the System of Environmental Economic Accounting - SEEA 2012. The EU should open up its 
databases that collect environmental reporting data and make those re-usable. This data is critical 
for financing, and to track the economic performance of sustainable activities. 

Such data should be gathered and made available digitally to users of non-financial information, 
not only investors, but also lenders, academia, researchers, authorities and others. To facilitate 
the collection, a certain level of standardization would be necessary. Finally, data should be 
provided to users ideally free of charge.

The availability of raw harmonized ESG data would allow for better comparability, 
increase transparency, lower barriers and costs, generate efficiency, reduce complexity
and attract new players. The data register would provide a very valuable source of information 
to markets and policy makers alike. Such database should also help data preparers by eliminating 
current multiple different requests.

We thank you for your attention and remain available to discuss further. In the meantime, we 
would be pleased to receive your preliminary views, as our Associations continue working on this 
project.