Response to the Commission's Call for Evidence on SFDR

We focus on 5 critical issues the revision of the SFDR should address :  

1. Any new approach to sustainable financial product categorisation must be based on retail investors’ sustainability-related objectives and integrate the concept of “investor impact”/”impact generating investments”
2. Adapt the MiFID II/IDD sustainability preference categories to the new SFDR categorisation approach and clarify the definition of sustainability-related objectives at the earliest opportunity
3. Alongside any technical clarification of definitions and concepts in the SFDR, care must also be taken to ensure retail investors are furnished with adequate and easily understandable information about financial products
4. Ensure strong adherence to the better regulation principles and avoid earlier pitfalls which materialised with concurrent development of sustainable finance regulation under the Action Plan
5. Any review of PAI indicators must also address the current concerns about lack of reliability in relation to quantitative data which is reported