The European Association of Co-operative Banks appreciates the possibility to provide feedback on the Usability of the EU Taxonomy. We strongly believe that substantial steps to enable a more sustainable economy are inevitable for the future of our society and we support the Commission´s intention that the financial industry can contribute to improve the current situation by redirecting capital flows to sustainable investments. Contributions from other stakeholders is required as well. The development of a sustainable economy is mainly the responsibility of the productive sectors, with financial market participants and banks playing a complementary and important role as well.
Having said that we are absolutely convinced that – due to the current structure of the European economy, which is based predominantly on SMEs – the Commission’s approach to address both ways of financing – bank financing and capital markets – is the appropriate way forward; this has been reflected in the respective action plan issued in March 2018.
This view has been blurred by the actual draft of the TEG-report for the taxonomy (and especially in the Addendum “Using the Taxonomy”) which is explicitly addressed to capital market participants, mainly Asset Managers.
If the political intention to redirect financial resources within a short period of time to sustainable investments is still valid, we urge to put more emphasis on the traditional way of bank-financing, which will allow to address the full range of market participants in the economy as well as enable a more direct impact of sustainable investments.
The EACB appreciates the proposal that the taxonomy should not be a mandatory framework for financial market participants and be based on the principle of voluntary usage, ideally based on incentives. We hope that our considerations could
Having said that, we hope that the co-operative banks’ point of view could be integrated into the final TEG report on the EU Taxonomy.
To see our responses to the Consultation in detail please see the attached document.
For further information or questions on this paper, please contact:
Ms. E. Bevilacqua, firstname.lastname@example.org
Mr. G. Betti, email@example.com