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IIGCC submits response to European Commission’s SFDR consultation

IIGCC submits response to European Commission’s SFDR consultation

IIGCC has submitted its response to the European Commission’s consultation on the implementation of the Sustainable Finance Disclosure Regulation (SFDR). A number of IIGCC members shared feedback and input, which is reflected in our final consultation response.

IIGCC welcomes the overarching aims and intent of the SFDR. However, investors have faced a number of challenges and barriers in relation to their implementation of the SFDR, and we welcome this wide-ranging review that we hope will help to improve the functioning and clarity of the framework. In particular, we urge the Commission to consider and account for the following positions and recommendations:


  • Clarifying the definition of 'sustainable investments' under SFDR and adequately accounting for investment in transitioning assets
  • Clear categories and criteria for products pursuing sustainable objectives or promoting environmental / social characteristics 
  • Addressing usability and implementation challenges within the existing framework
  • Promoting interoperability with wider disclosure regimes

About the consultation

The Commission’s consultation aims to gather information from a wide range of stakeholders on their experiences with the implementation of the SFDR. The Commission is interested in understanding how the SFDR has been implemented and any potential shortcomings, including in its interaction with the other parts of the European framework for sustainable finance, and in exploring possible options to improve the framework. The main topics covered in the consultation are:


  • Current requirements of the SFDR
  • Interaction with other sustainable finance legislation
  • Potential changes to the disclosure requirements for financial market participants
  • Potential establishment of a categorisation system for financial products

DISCLAIMER: This response was developed by IIGCC with input from some members, but does not necessarily represent the views of the entire membership, either individually or collectively.