PensionsEurope welcomes the European Commission’s proposal on ESG ratings. This legislation provides many solutions to current market shortcomings, such as enhancing transparency on methodologies and operations, regulating conflict of interests, establishing rules for third-country providers, and providing specific measures for smaller ESG providers. However, we believe that some areas in the proposal for ESG rating activities need further clarification and amendments. In particular, we argue that ESG data providers should be included in the scope of the proposal. We also advocate for greater transparency on the free structure by providers. The oligopolistic nature of the ESG rating market is another point of concern, which requires additional intervention by the European Commission, e.g. on licensing and contractual matters.