Our response emphasises the importance of upholding coherence between SFDR and wider components of the EU's regulatory framework, clarifying key concepts, and tackling implementation issues. Alongside broad support for the aims of the review, we offer recommendations based on member feedback.
On 2 May, the European Commission launched a Call for Evidence (CfE) on the review of the Sustainable Finance Disclosure Regulation (SFDR) regarding the simplification of regulation to improve clarity, remove inconsistencies and address issues relating to data availability. Feedback received will inform the wider, comprehensive review of the SFDR which is scheduled for publication in Q4 2025.
IIGCC submitted a response to the CfE on 30 May. We support the broad aims of the SFDR review, which should help to address usability and implementation challenges while also preserving the regulation’s objectives to promote transparency and channel finance towards sustainability-focused investment strategies.
Our key recommendations:
- Consider interlinkages between the SFDR review and wider initiatives to revise the sustainable finance framework, most notably the Omnibus Package, and ensure amendments made to wider reporting standards, are reflected in changes to SFDR.
- Provide clarity and standardisation on key concepts, most notably the definition of 'sustainable investments' to acknowledge the critical role of investment in transitioning assets.
- Focus entity-level disclosures on information that is most meaningful to report at this level, and avoid overlapping or duplicative requirements between SFDR and CSRD.
- Prioritise interoperability with wider regimes, including the UK Financial Conduct Authority's Sustainability Disclosure Requirements (SDR) and labelling regime.
Alongside IIGCC's feedback, we also contributed to the submission of a supplementary real estate response under the ARESI initiative. The initiative brings together leading industry organisations, including IIGCC, AREF, INREV, EPRA, RICS, and others, to align assumptions and methodologies without creating new standards or further fragmenting the market.
IIGCC members: if you have any questions, or would like to join our EU policy working group, please reach out to Hajira Kamran through the member newsletter.