“This renewed strategy should be an opportunity to ensure a certain coherence of the existing framework”Saïf Chaïbi, policy adviser at PensionsEuropePensionsEurope expressed a similar hope to Efama’s about the Commission’s new strategy.“This renewed strategy should be an opportunity to strengthen the link between all the developments so far and ensure a certain coherence of the existing framework,” said Saïf Chaïbi, policy adviser at PensionsEurope.“This would be to enable pension funds and other investors to comply with the new requirements.” Asset managers and pension providers face a host of new disclosure requirements under the so-called taxonomy and disclosures regulations, two of the three new regulations stemming from the Commission’s original sustainable finance strategy. For products with a sustainability flavour, for example, the taxonomy regulation introduces a requirement to report on the proportion invested in activities that count as “green” under the taxonomy. The rules defining the content of disclosures under the disclosures regulation have yet to be published, but are keenly anticipated and expected in draft form for consultation soon. ESG data register mention pleasesA potentially promising aspect of the Commission’s consultation, according to Chaïbi, is that it “opens the debate on the possibility of establishing a European register of ESG data on companies”.“Moreover, it would be open source, meaning you wouldn’t have to pay to have access to the data,” he said.In the consultation document, the Commission stated that “it may be useful to ensure open and centralised access not only to company reporting under the NFRD, but also to relevant company information on other available ESG metrics and data points”.“To this end, a common database would ease transparency and comparability, while avoiding duplication of data collection efforts,” it said before asking for views on whether it should take action on such an idea.Efama said it welcomed the Commission’s “intention to improve ESG disclosure by investee companies, as well as the market for ESG data and ratings”.It is also encouraged by the Commission posing questions about facilitating shareholder engagement and cross-border voting, which the industry body argues would help develop sustainability and a more long-term focus in capital markets.In the consultation document, the Commission asks for views on whether voting frameworks across the EU should be further harmonised at EU level to facilitate shareholder engagement and votes on ESG issues. Another question asks “Do you think EU action is necessary to allow investors to vote on a company’s environmental and social strategies or performance?”.Other aspects appeared to be less pleasing. It said financial literacy and promoting sustainability awareness were ” somewhat sidelined in the consultation, despite being key for unleashing the full potential of sustainable finance”.“While asset managers play an important role in providing investors with the information they need to make informed decisions, ultimately it is the investor who makes investment decisions,” it argued. The Commission’s consultation is available here. The deadline for responses, via an online questionnaire, is 15 July. The Commission also asks “more generally, how can pension providers contribute to the achievement of the EU’s climate and environmental goals in a more proactive way, also in the interest of their own sustained long-term perfomance?”.“How can the EU facilitate the participation of pension providers in such a transition?,” it adds.The EC has spoken of creating an “enabling framework” to stimulate private and public investment in support of its green economic growth plan – the Green Deal. The Commission launched the consultation on what it calls its “renewed” sustainable finance strategy before the Easter weekend. It is split between a short section of questions aimed at “all stakeholders”, including citizens, and a long section aimed at experts. As the Commission says itself, the consultation covers a diversity of topics. These include the development of a system for determining environmentally harmful economic activities – a “brown” taxonomy – , financial accounting standards, investment protection, the EU green bond standard, and the market for ESG ratings, data and research. It also appears to ask for views about the EU establishing a label for ESG or green funds aimed at professional investors.There are also questions about extending the taxonomy – currently a framework for determining what counts as a “green” economic activity – to social objectives and whether the taxonomy should play in EU public spending programmes.“The consultation substantially widens the strategic scope of Europe’s sustainable finance policy”Climate change think tank E3GClimate change think tank E3G said the consultation “substantially widens the strategic scope of Europe’s sustainable finance policy”.“It proposes new actions for both public and private finance institutions, and puts forward an ambitious global dimension with a strong role for Europe’s external financial mechanisms,” it said. The Commission has said that, building on the achievements of its 2018 sustainable finance action plan, “the current context requires a more comprehensive and ambitious strategy”. ‘Opportunity for more coherence’In an initial reaction to the consultation, Efama, the European investment management industry body, said it was right that the topic of sustainable finance remained very high on the EU agenda, but expressed a hope for ”a more holistic and consistent approach”.”Thanks to the 2018 sustainable finance action plan, we already have in place a framework to integrate sustainability,” it said. “As many legislative proposals were developed in parallel, some inconsistencies and gaps have emerged.“The renewed strategy needs to put the different pieces of the puzzle together and make the new rules work in practice, in a well sequenced, consistent and coordinated manner.”Aleksandra Palinska, senior regulatory policy advisor at Efama, said: ”The biggest challenge is that in a first instance you need ESG data disclosure from investee companies and although the data is supposed to become more available with the Non-Financial Reporting Directive (NFRD) review, the Commission proposal is expected only towards the end of this year, with the rules not likely to take effect before a couple of years’ time.”The Commission recently launched the second part of a two-stage consultation process on the future of the NFRD.Palinska said the late-stage insertion in the taxonomy regulation of reporting requirements for certain large companies was welcome, “but those obligations will kick in at the same time as the obligations for asset managers to disclose”. “So in a way it’s too late because asset managers need those disclosures to prepare theirs, so here the sequencing is very much off,” she said. “There is a lot of uncertainty in the industry and we would very much like a more consistent and holistic approach to enable a proper implementation of the requirements that have been introduced.” The European Commission has included in its wide-ranging new sustainable finance consultation a question that paves the way for views about the possible need for amendments to EU pension fund legislation with regard to member views on environmental, social and governance (ESG) matters.The question asks whether, in light of the planned review of the IORP II Directive in 2023, the EU should “further improve the integration of members’ and beneficiaries’ ESG preferences in the investment strategies and the management and governance of IORPs?”.If respondents choose to answer yes, they are asked how this could be achieved given that members in collective schemes may have diverging views on ESG integration.Another question asks if the EU should “explore options to improve ESG integration and reporting beyond what is currently required by the regulatory framework for pension providers”.
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