Our main requirements for the new strategy of the EU Commission
With its consultation on "Renewed Sustainable Finance Strategy", the EU Commission wants to review the effects of EU measures and adapt them to the EU's more stringent climate targets. In our statement (Long version / Short version) we have formulated the following key demands:
- We strongly support the basic idea of the EU Action Plan of 2018 to promote sustainable investment by providing incentives and relying on voluntary commitment by investors. We therefore consider that regulatory measures prohibiting, or stigmatising as "brown", investments in companies, which are not in breach of any EU or national law, are wrong. Instead, where the EU legislator regards corporate activities as open to criticism it should take appropriate action directly.
- Although we are in favour of an EU-wide Eco-Label, we fear that the eco-labelling criteria are far too ambitious. This is particularly true of the thresholds being discussed for green investments in accordance with taxonomy and of the long lists of exclusion criteria. These would considerably restrict the investment universe and with it risk diversification.
- We see the risk of overlapping, inconsistent and fragmented sustainability rules. For example, the timing of the application of SFDR does not allow for proper implementation of ESG disclosure requirements. Due to the time gap between the application of disclosure requirements for financial products and the availability of the necessary relevant corporate data, there is a risk that sales of sustainable products will to be discontinued.
- In future, asset managers will be subject to the requirements of the EU Disclosure Regulation and the Taxonomy Regulation, among others. However, in order to incorporate ESG factors into their investment decisions and to assess correctly the sustainability risks and opportunities of their investments, it will also be necessary to revise the EU requirements for non-financial reporting by companies. Companies must be required to publish comparable and information on their economic activities and the resulting impact on the sustainability factors.
- Small investors who are indifferent to sustainability criteria, or who even explicitly state that they are only interested in financial returns, should not be pushed into sustainable investment products. This contradicts the basic approach of the EU Action Plan to promote voluntary investment in sustainable activities and to create incentives to achieve this. Ultimately, it must be up to the investor to decide if he wants to finance sustainable projects by way of his investment.