In a letter to EC, Steven Maijoor, the Chair of the Joint Committee of ESAs, mentioned several important areas of uncertainty in the interpretation of the Sustainable Finance Disclosure Regulation (SFDR or Regulation 2019/2088). These areas of uncertainty relate to the questions raised by stakeholders during the consultation process for draft regulatory technical standards for the content, methodologies, and presentation of disclosures pursuant to SFDR. The letter outlines certain priority questions that would benefit from a more urgent clarification, to facilitate an orderly application of SFDR from March 10, 2021. ESAs look forward to hearing from EC in this matter.
The Annex to the letter elaborates on these priority areas of SFDR, which cover the:
- Application of SFDR to non-EU and registered Alternative Investment Fund Managers, or AIFMs
- Application of the 500-employee threshold for principal adverse impact reporting on parent undertakings of a large group
- Meaning of “promotion” in the context of products promoting environmental or social characteristics
- Application of Article 9 of SFDR on transparency of sustainable investments in pre‐contractual disclosures
- Application of SFDR product rules to portfolios and dedicated funds
Related Link: Letter (PDF)
Keywords: Europe, EU, Banking, Insurance, Securities, SFDR, Sustainable Finance, Disclosure, ESG, Regulation 2019/2088, Sustainability-Related Disclosures, Climate Change Risk, EC, ESAs
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
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