About this initiative

Summary

In the context of the Commission work on sustainable finance, this initiative aims at strengthening financial stability and asset pricing by clarifying that institutional investors and investment managers have a duty to consider the materiality of sustainability factors.

Topic
Banking and financial services
Type of act
Provisional data
Expert group

Roadmap

Feedback: closed
Type

Inception impact assessment
More about roadmaps.

Feedback period
13 November 2017 - 11 December 2017
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Download (308.9 KB - PDF - 4 pages)

Feedback (9)

  • Invest Europe (Belgium)
    11 December 2017 Other
    Invest Europe (Belgium)

    Invest Europe supports the Commission’s (EC) work to ensure that material sustainability factors are assessed, consistently taken into account and disclosed by institutional investors and asset managers. However, it is crucial that an accepted definition of “sustainability” (eg Brundtland report) is used and the scope captures all aspects of sustainability (climate change, environment, social & governance). We should be careful not to...

  • INVERCO (Spain)
    11 December 2017 Business association
    INVERCO (Spain)

    INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle. From our point of view, there should not be any compulsory ESG rules in the investment strategy/asset allocation,...

  • Anonymous (Spain)
    11 December 2017 Business association
    Anonymous (Spain)

    INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle. From our point of view, there should not be any compulsory ESG rules in the investment strategy/asset allocation,...

All feedback (9) >

Draft act

Feedback: closed
Type

Draft delegated regulation
More about draft acts

Feedback period
24 May 2018 - 21 June 2018
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Download (382.6 KB - PDF - 9 pages)

Feedback (20)

  • BETTER FINANCE (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    BETTER FINANCE (Belgium)

    BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/2359 to include the customer’s ESG preferences in the criteria and practical details to be taken into account by insurance intermediaries and insurance undertakings when assessing the suitability of insurance-based investment products for their customers. Investment firms shall act in accordance with the best interest of their clients...

  • 2°Investing Initiative (Germany)
    21 June 2018 Non-governmental organisation (NGO)
    2°Investing Initiative (Germany)

    For our feedback please see the attached file.

  • Finance Watch (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    Finance Watch (Belgium)

    The concept of “best interest” should be defined at the EU level to include both financial and non-financial benefits. In other words, we believe that it should be made clear that the utility of investors can depend on both financial and non-financial returns. This is particularly critical if we think about the long-term impacts of climate change on future generations and the weaknesses in the current environmental legislations, which do not...

All feedback (20) >
Feedback: closed
Type

Draft delegated regulation
More about draft acts

Feedback period
24 May 2018 - 21 June 2018
View feedback received >
Download (386.3 KB - PDF - 10 pages)

Feedback (53)

  • Managed Funds Association (United States)
    21 June 2018 Business association
    Managed Funds Association (United States)

    Managed Funds Association (“MFA”) welcomes the opportunity to provide comments to the European Commission (the “Commission”) on its proposal for a delegated regulation as regards organisational requirements and operating conditions for investment firms (the “Draft Delegated Regulation”). MFA supports the European Commission’s aim of promoting sustainable finance within the EU, and of closing the investment gap required to meet European...

  • BETTER FINANCE (Belgium)
    21 June 2018 Non-governmental organisation (NGO)
    BETTER FINANCE (Belgium)

    BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organizational requirements and operating conditions for investment firms and defined terms for the purpose of that directive. Investment firms shall act in accordance with the best interest of their clients. As such, when providing investment advice and portfolio management, they must disclose...

  • French Asset Management Association (Association Française de la Gestion financière, AFG) (France)
    21 June 2018 Business association
    French Asset Management Association (Association Française de la Gestion financière, AFG) (France)

    AFG decided very early on to fully support the development of responsible investment in France. French asset management companies are fully committed to this approach and are adapting their offering to the concerns of their institutional and private investors by proposing products that entail varying degrees and types of commitment – SRI funds, integration of ESG criteria, shareholder engagement, thematic investing and so on – and have in...

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Commission adoption

Feedback: closed
Type

Proposal for a regulation
More about adopted acts

Adopted on
24 May 2018
Feedback period
24 May 2018 - 22 August 2018
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Download (419.5 KB - PDF - 19 pages)
Download (107 KB - PDF - 3 pages)

Feedback (35)

  • ISDA and AFME (Belgium)
    23 August 2018 Business association
    ISDA and AFME (Belgium)

    Executive Summary ISDA and AFME support the European Commission’s efforts to enhance transparency and comparability regarding low carbon and positive carbon impact benchmarks. We welcome the draft proposal for a Regulation. ISDA and AFME believe that in order for capital to flow towards low carbon or positive carbon impact economic activities, a flexible approach needs to be taken in the development of EU low carbon and positive carbon impact...

  • 2° Investing Initiative (France)
    22 August 2018 Non-governmental organisation (NGO)
    2° Investing Initiative (France)

    Summary: With this proposed regulation, the EC aims at regulating the construction of benchmark indices that seek to ensure a representation of what a market compatible with a well below 2°C scenario would look like today, in order to protect investors from greenwashing and support the transition to a low carbon economy. 2° Investing Initiative strongly supports the general objective of preventing greenwashing in sustainable finance, promoting...

  • ABN AMRO (Netherlands)
    22 August 2018 Company/business organisation
    ABN AMRO (Netherlands)

    At ABN AMRO we welcome the European Commisions proposal on the establishment of a framework to facilitate sustainable investment. Sustainability is an integral part of business at our bank. Together with our clients we are working on making their real estate more sustainable, we aim to accelerate the transition to the circular economy and we are making sustainable investments mainstream. We are eager to work together on a framework that...

All feedback (35) >
Feedback: closed
Type

Proposal for a regulation
More about adopted acts

Adopted on
24 May 2018
Feedback period
25 May 2018 - 23 August 2018
View feedback received >
Download (421.9 KB - PDF - 27 pages)

Feedback (52)

  • 2° investing Initiative (France)
    23 August 2018 Non-governmental organisation (NGO)
    2° investing Initiative (France)

    ABOUT US 2° Investing Initiative is a non-for-profit, non-commercial organization based in Paris, London, Berlin and New York City. It is the leading research center on climate-related metrics for financial markets globally, and notably leads most EU-funded research projects on the topic. It regularly produces analysis and policy recommendations on the topic of financial institutions climate disclosures. 2° Investing Initiative has been...

  • The Investment Association (United Kingdom)
    23 August 2018 Business association
    The Investment Association (United Kingdom)

    The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which will be of key importance in the promotion and development of sustainable finance throughout Europe and across the globe. The IA represents 250 UK-based investment management firms who collectively manage funds totalling EUR 8.1 trillion, of which EUR 2 trillion is on behalf of European clients. The...

  • BETTER FINANCE (Belgium)
    23 August 2018 Non-governmental organisation (NGO)
    BETTER FINANCE (Belgium)

    BETTER FINANCE welcomes this opportunity to comment on the European Commission’s regulation proposal on disclosure relating to sustainable investment and sustainability risks (amending Directive (EU) 2016/2341). EU citizens as savers and individual investors are the main provider of long term funding to the EU economy and are mostly by nature long term oriented, as their needs are often long-term ones: pension, home purchase, children...

All feedback (52) >
Feedback: closed
Type

Proposal for a regulation
More about adopted acts

Adopted on
24 May 2018
Feedback period
25 May 2018 - 23 August 2018
View feedback received >
Download (1.4 MB - PDF - 64 pages)
Download (228 KB - PDF - 4 pages)
Download (795.2 KB - PDF - 17 pages)
Download (3.6 MB - PDF - 200 pages)

Feedback (59)

  • 2° Investing Initiative (France)
    24 August 2018 Non-governmental organisation (NGO)
    2° Investing Initiative (France)

    ABOUT US 2° Investing Initiative is a non-for-profit, non-commercial organization based in Paris, London, Berlin and New York City. It is the leading research center on climate-related metrics for financial markets globally, and notably lead the EC-funded project "Sustainable Energy Investment Metrics" (H2020) that aimed at defining scientifically what is a "sustainable investment" in energy-related sectors. 2° Investing Initiative has been...

  • Expert/consultant/researcher on sustainable finance - Brazilian/Italian citizen (Brazil)
    23 August 2018 Other
    Expert/consultant/researcher on sustainable finance - Brazilian/Italian citizen (Brazil)

    Feedback of "Sustainable Inclusive Solutions" on the proposal for the “establishment of a framework to facilitate sustainable investment" The idea behind the proposal is to encourage green and social investments, ensuring credibility and comparison across the market. This is a completely appropriate course of action, but it might not provide enough incentives to reallocate current investments from unsustainable activities to sustainable ones....

  • WWF European Policy Office (Belgium)
    23 August 2018 Non-governmental organisation (NGO)
    WWF European Policy Office (Belgium)

    WWF European Policy Office welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. It is a positive step of the Commission, consistent with the EU Sustainable Finance Action Plan. We would like to make the following comments to the Commission’s legislative proposal: 1. We believe that this legislative proposal is a key opportunity...

All feedback (59) >

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