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
On Friday, 30 May 2025, the European Association of Paritarian Institutions (AEIP) submitted its response to the European Commission call for evidence on the revision of EU rules on sustainable finance disclosure.
In our input, we advocate for the upcoming review of the SFDR to be consistent with the simplification and streamlining approach proposed under the Omnibus package, particularly with the proposed amendments to the content of sustainability disclosure rules under the CSRD.
In addition, AEIP highlights the need to adapt reporting requirements to better reflect the unique needs and features of pension funds. Unlike other financial market participants (FMPs), pension funds usually hold a more diversified portfolio, and they typically offer only a single product, i.e. the pension scheme. The current disclosure rules impose a significant burden for pension funds, and do not provide additional value to members and beneficiaries. The revision of the SFDR represents an opportunity to reconsider the current horizontal approach to reporting requirements, and to ensure that rules are better tailored to pension funds.
AEIP also stresses that the current disclosure framework under Articles 8 and 9 has resulted in sustainability-related information that is often unclear and difficult to understand. We would welcome the introduction of a voluntary categorisation system, allowing FMPs to publish sustainability-related information outside the regulatory communication channels of the SFDR when their products do not fall into any category.
To read our full input please see here.
Our input is also available at the ‘Have your Say’ portal here.