The EACB has submitted its response to the consultation of the European Supervisory Authorities (ESAs) on the review of the SFDR Delegated Regulation regarding PAI and financial product disclosures. We welcome the ESAs proposals to clarify and streamline the disclosure requirements under the SFDR, and the efforts to align with the existing – and incoming – sustainable finance legislation in particular. Nonetheless, the EACB would like to highlight the following general comments:
- Maximum coherence throughout the regulatory framework is key to achieve the goals pursued: It is important to align the SFDR RTS disclosure requirements with the new European Sustainability Reporting Standards coming into effect under the CSRD.
- Ensure a strong legal basis under SFDR Level 1: Since the review of SFDR Level 1 is imminent, the European cooperative banks respectfully ask the ESAs to reconsider any changes to the current RTS that would imply costly and burdensome implementation, for limited benefits in the short term. Financial market participants have been making significant efforts in recent months to create the PAI statement based on the current SFDR disclosure requirements, and investors have only recently familiarised themselves with the format of disclosures. Therefore, the EACB takes the view that any overarching changes to the SFDR framework should be reserved for the level 1 review, which will provide a more appropriate context for discussion.
- Refrain from introducing new PAIs at this early stage: While alignment with related legislations and technical corrections are welcome, the EACB is wary at this stage of the adoption of further PAIs. We understand that the ESAs have been mandated to propose changes at this time, however further implementation of the current sustainable finance framework is needed before any changes can be brought to SFDR level 2 in a meaningful way.
For more detailed responses, please download our position paper.