Our contribution to the EU Commission’s SFDR consultation

December 20, 2023

Climate & Company contributed to the EU Commission’s targeted consultation on the Sustainable Finance Disclosure Regulation (SFDR): 

In line with many peers, we’ve actively contributed to the European Commission’s Sustainable Finance Disclosure Regulation (SFDR) consultation. Find out about our answers here.

Here’s a sneak peek at our main findings: 

  • Alignment with other legislation: Our focus centers on the alignment between the SFDR and the CSRD/ESRS. We advocate for three key points: (1) Keep mandatory PAI indicators in the SFDR; (2) Maximize alignment between indicators across both files; (3) The SFDR is yet another reason for the need for timely adoption of ESRS sector standards. 
  • Entity and Product Level Disclosure: We welcome the progress made towards standardised disclosure requirements for entities and financial products. However, we stress the importance of clear guidance, practical implementation and digital accessibility of sustainability disclosure for financial market participants. These aspects are crucial for effective transparency.  
  • Product Categories: The introduction of new product categories, aligning with developments in other jurisdictions, and catering to retail investors’ preferences for sustainable financial products, is indeed a welcomed step. However, it is essential that these product categories, and in particular “products with a transition focus”, are accompanied by minimum criteria and transparent disclosure requirements. See for example AFM’s position paper (link). We will continue to work on defining the characteristics of viable and ambitious transition products and are eager to share our progress next year. 

This is a real opportunity to reshape the landscape of sustainable finance in the EU – and we’ll clearly be watching the future developments.