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AEIP gives its input to the ESAs joint consultation on ESG disclosures

Homepage News AEIP gives its input to the ESAs joint consultation on ESG disclosures

AEIP gives its input to the ESAs joint consultation on ESG disclosures

Cécile Henrotte
02/09/2020
News

AEIP responded to the joint consultation of the European Supervisory Authorities (ESAs) regarding the development of Regulatory Technical Standards (RTS) for the ESG disclosures Regulation. AEIP has welcomed the opportunity to provide input and gave its feedback on a series of points. We appreciate the action of the ESAs to highlight to the European Commission the extremely tight implementation deadline, since we are concerned that our members will not be able to achieve compliance with the SFDR within the timespan between the adoption of the Regulatory Technical Timeline and the 11 of March 2021. At the same time, we believe that regulators should aim for consistent principles and requirements across different parts of the EU Sustainable Finance agenda, since, for example, the proposed set of the so-called ‘adverse impact indicators’ is namely not aligned with the ‘do-no-significant-harm’ criteria introduced by the Taxonomy Regulation.

 

Importantly, the best effort approach to obtain data from companies does not reflect the operational realities of pension funds. Article 7(2)a implies that financial market participants should first aim to obtain any missing data on the adverse impact indicators from investee companies. In reality, financial market participants will rely on external data suppliers that will collect data directly from investee companies or conduct their own research to arrive at reasonable estimates. Furthermore, the RTS seem to be designed for fairly simple retail funds, consisting mainly of listed equity and fixed income securities, for which a lot of data is already available. Pension funds’ portfolios are more complex and encompass all types of (long, non-leveraged) assets, including private equity, real estate, infrastructure, private debt, securitized assets and commodities. While these alternative assets only represent a minor part of the portfolio, reporting is required against all assets. While recognize the benefit of considering the social and environmental impact of some of these categories of assets, data is often completely missing. Moreover, the administrative burden of full compliance against the concept RTS therefore may be much higher for a pension funds than e.g. retail fund managers.

 

For AEIP’s full input to the ESAs joint consultation, please see here.

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  • AEIP responds to European Commission Call for Evidence on the European Pillar of Social Rights Action Plan 2025
  • Paritarian model key to pension adequacy: AEIP response to EU consultation on supplementary pensions
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  • AEIP announces newly elected President, Vice-President, and Board Members
  • AEIP input on integration of EU capital markets: supervision of pension funds should remain at national level
  • AEIP welcomes the European Parliament’s proposed amendments for a directive harmonizing certain aspects of insolvency law
  • AEIP input on the revision of EU rules on sustainable finance disclosure: need to consider the features and needs of pension funds in the context of the SFDR review
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Tuesday, 9, Sep
AEIP responds to European Commission Call for Evidence on the European Pillar of Social Rights Action Plan 2025
Friday, 29, Aug
Paritarian model key to pension adequacy: AEIP response to EU consultation on supplementary pensions
Monday, 30, Jun
AEIP is pleased to publish its activities carried out throughout 2024.
Thursday, 26, Jun
AEIP announces newly elected President, Vice-President, and Board Members
Friday, 20, Jun
AEIP input on integration of EU capital markets: supervision of pension funds should remain at national level
Thursday, 12, Jun
AEIP welcomes the European Parliament’s proposed amendments for a directive harmonizing certain aspects of insolvency law

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