EFAMA shares the urgent need to improve the consistency and comparability of sustainability reporting at a global level. Therefore, we welcome the opportunity to respond to the ISSB consultation on the Exposure Drafts on “General Requirements for Disclosure of Sustainability Related Financial Information” (IFRS S1) and on “Climate-Related Disclosures” (IFRS S2).
The asset management industry plays a key role in meeting the objectives of the European Green Deal to make the EU’s economy sustainable. Our members integrate ESG considerations across their risk management processes and investment decisions. They develop sustainable investment products and foster transparency to fight greenwashing. This increases choice, trust and, in turn, retail investors’ participation. Overall, such efforts mobilise capital towards a fair and just transition to a climate-neutral economy by 2050.
EFAMA actively contributes to the development and implementation of EU’s sustainable finance initiatives. Among them are a comprehensive transparency framework for financial market participants, standards and labels for green financial products, classification of green economic activities and policies enhancing corporate sustainability reporting.
EFAMA strongly supports the initiative carried out by EFRAG with the publication of the Exposure Drafts on the European Sustainability Reporting Standards (ESRS). The Exposure Drafts provide key elements framing the architecture of reporting requirements and clarifying the content and key concepts of CSRD. The resulting data will be of crucial importance for investors and for achieving the EU objective to transition towards a zero emissions economy by 2050.
EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the functioning of the ESG rating market in the EU and on the consideration of ESG factors in credit ratings. Please note that our response covers, at the same time, ESG ratings and ESG data providers, as the demand for ESG “raw” data has been increasing at a steady pace. The use of ESG data has also rapidly shifted from a narrow set of investment products to being prolific across all investment products.
The European ESG Template (EET) is meant to facilitate the necessary exchange of data between product manufacturer and distributor for the purpose of fulfilling ESG-related regulatory requirements contained in the SFDR, relevant provisions of the Taxonomy Regulation, and the relevant delegated acts complementing MiFID II and IDD. The EET V1 is based on the regulatory situation on the day of publication and will be reviewed regularly depending on the evolving regulation, and at least confirmed annually. With regard to the MiFID target market, the EET interacts with the EMT V4.
On behalf of:
CDP, Economy for the Common Good, EFAMA, Eurosif, Frank Bold, Finance Watch, Global Witness, Investor Alliance for Human Rights, Publish What You Pay, ShareAction, Transport and Environment, WWF
Naïm Abou-Jaoudé, EFAMA President, comments: