On 15 December 2023, PensionsEurope answered the European Commission’s Targeted Consultation Document on the implementation of the Sustainable Finance Disclosures Regulation (SFDR).
We support the European Commission’s overall ambition of financing the transition of the broader economy by raising the bar for reporting on sustainability issues through various instruments, including SFDR.
However, the application of the SFDR has presented many implementation issues for pension funds, which we elaborate on in our response. To address these challenges, we encourage the creation of a dedicated sub-sectoral Regulatory Technical Standard (RTS) within the SFDR framework tailored to pension funds and their specificities.
We also agree with the EC’s assessment that Articles 8 and 9 and their current use as a labelling scheme might lead to greenwashing risks. We advocate for the establishment of a voluntary EU-level product categorisation system to effectively address this concern. While transforming existing Articles into formal categories could potentially mitigate this issue, it would require careful design and might not entirely resolve the confusion around disclosures. Considering this, an alternative approach might prove more suitable, but would have higher implementation costs compared to consolidating existing principles.
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