On 3 July 2023, ESBG responded to the ESAs (the three European Supervisory Authorities: EBA, EIOPA and ESMA) Consultation Paper on the review of the Sustainable Finance Disclosure Regulation (SFDR) Delegated Regulation regarding PAI and financial product disclosures.

Overall, even though ESBG welcomes the objective to clarify the current framework as well as to make it more workable, we are stressing that implementing changes comes at a high economic expense, hence future changes must be considered carefully.

Moreover, defining a sustainable investment should be a priority and the prerequisite to all regulations concerning ESG products. It would enable product comparability and legal protection against greenwashing risk.

ESBG believes that the inclusion of new mandatory social indicators might not currently be the main priority given the lack of data and common measurement methodology. More clarity is needed regarding the definition and metrics of the proposed mandatory social indicators. Indeed, the existing PAIs already cover quite a wide range of issues.

On a more general note, ESBG kindly asks to consider very carefully any future changes to:
• avoid adding an extra layer of complexity to the current framework;
• avoid making it even more difficult to implement for financial market participants and;
• avoid causing fatigue to customers with new information/requirements in a short period of time.

Executive SummaryRead the full letter here


Adrien Boudet- Associate Advisor-Sustainable Finance
e.: adrien.boudet@wsbi-esbg.org
t.: +32 2 211 11 63