On 14 November, PensionsEurope published its position paper on the SFDR Level 1 review, focusing particularly on the ESAs’ Joint Opinion on the SFDR. We emphasise that the SFDR review should aim to improve the existing framework and make it more fit for purpose. The current structure presents significant implementation challenges for pension funds and does not take into account their specificities. We, therefore, advocate for IORPs to be governed under a dedicated sub-sectoral RTS within the SFDR framework dedicated to IORPs tailored to their unique characteristics.
We also highlight that the review should prioritise simplifying the framework. It is important to acknowledge the costs that FMPs including IORPs have already incurred large costs to meet SFDR requirements. We are concerned that introducing product categories may inadvertently increase regulatory burdens for IORPs, even for those outside of these categories, as they could be placed under a “non-category,” leading to further reporting requirements and complexity.
However, if the framework does move toward categorisation, we strongly support introducing a transition category. We also advocate for the recognition of engagement and exclusion strategies in the categorisation system and for a streamlined list of mandatory PAIs.
Our answer is available below.
