Newsletter of September 2022
Newsletter 2022/04 - Topic 4
Newsletter 2022/04 - Topic 3
Newsletter 2022/04 - Topic 2
Newsletter 2022/04 - Topic 1
PensionsEurope welcomes the opportunity to comment on the Platform on Sustainable Finance’s paper about Minimum Safeguards (MS). The Report proposes two sets of criteria for the establishment of non-compliance with MS: one related to adequate due diligence processes implemented in companies (i.e. relying on corporate reporting and disclosure) and the other related to the actual outcome of these processes or the company’s performance (i.e. relying on external checks on companies). PensionsEurope acknowledges that the Report tries to be as clear and thorough as possible, however minimum safeguards definitions could lead to differences in interpretation. Therefore, clarity and consistency should remain key elements during the development of MS. See our comments in detail.
PensionsEurope welcomes the opportunity to comment on the EFRAG’s exposure draft on the Draft European Sustainability Reporting Standards. PensionsEurope supports the introduction of an EU level sustainability reporting framework. There is an increasing demand from pension funds for ESG data due to the growing sustainable investments of pension funds and the requirements for complying with European regulatory frameworks on sustainable finance.
We actively support some additional disclosure requirement on “workplace employee benefits’’ to better recognize private pensions, which will be open to all company's workforce, as an indicator of a good remuneration policy. Moreover, PensionsEurope supports and encourages consistency of reporting requirements and their alignment with requirements of other Sustainable Finance regulations and global frameworks. Finally, we believe that the upcoming framework should facilitate and recognise the difference between portfolio and company materiality.
In its input to EIOPA consultation on the review of IORPs reporting requirements, PensionsEurope e.g.:
- stresses that PensionsEurope appreciates reliable and good quality pension statistics and finds them important to IORPs, policymakers, and supervisors;
- finds that the review comes very early, as based on the new reporting requirements for IORPs, so far EIOPA has published only five quarterly statistics, one annual statistics, and hardly any public analysis;
- is concerned about the extra burden and costs of new requirements particularly to small and medium sized IORPs;
- recommends that further proportionate measures should be introduced.
The EU Sustainable Finance Strategy was published by the European Commission one year ago on 6 July 2021. It is built on previous initiatives and reports, such as the report of the High-Level Expert Group on Sustainable Finance and the subsequent legislative package in 2018. The Strategy sets out how it will support the EU Green Deal and Europe’s transition to becoming a carbon-neutral continent by 2050.
In our position paper on the EU sustainable finance - one year after, we explain our main positions on relevant topics and initiatives, including:
- Double materiality
- Extended taxonomy
- Social taxonomy
- Non-financial reporting and accounting standards
- Financial literacy
- Systemic risks
- ESG data
Find out more in our press release here.
Newsletter 2022/03 - Topic 7