On 4 July 2023, PensionsEurope answered to the ESA’s Joint Consultation Paper on the review of SFDR Delegated Regulation regarding PAI and financial product disclosures.
We welcome the ESA’s proposal to include social factors in PAI disclosures. However, the current data gap faced by FMPs needs to be considered before including any new mandatory social PAI. To solve this issue, we believe that further alignment between the SFDR and CSRD is necessary.
Moreover, some issues, such as the harmonisation of the DNSH framework should not be considered before any review of the SFDR level 1 as FMPs lack comparability under the current framework.
We also appreciate the efforts from the ESAs to simplify the disclosures’ publications, yet we believe that they remain too complex to understand for participants.
The PensionsEurope’s full answer is available below.
