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.

Given the increasingly important role ESG ratings and data products providers play in investment processes, EFAMA welcomes the increased attention of regulators to this issue. In light of the growing regulatory scrutiny on the ESG characteristics of potential investments, improving the usability and reliability of the ESG ratings and data products is a key priority for the European asset management industry.

EFAMA welcomes IOSCO's enhanced attention to transparency efforts supporting informed and qualified investment decisions in sustainability-related products. We support the adoption of such recommendations at the international level and believe IOSCO should leverage the experience with SFDR and Taxonomy in Europe to help establish consistent international standards, definitions and best practices.

In this response, we would like to highlight three pressing challenges deserving greater attention in the report from asset managers' perspective.