PensionsEurope submitted its response to the ESAs’ survey on their mandatory templates of pre-contractual and periodic disclosures for products that “promote” ESG characteristics and products with sustainability objectives (articles 8, 11 and 9 of the Sustainable Finance Disclosure Regulation, SFDR).

In its response, PensionsEurope emphasises that a highly standardised presentation of the information in product disclosures is undesirable as the templates seem to be designed for classic investment products and are therefore not adequate for most pension plans. The proposed draft RTS and templates do not provide any differentiation between the various types of financial products, although SFDR requires the ESAs’ to take account of  the various types of products and their characteristics when designing the new disclosure requirements and templates. 

The response also draws attention to the need to simplify the templates and rejects the graphical representations proposed in the illustrative mock-ups as they would not adequately reflect IORPs’ investment strategies and would therefore be somehow misleading.

You can read our response to the ESAs' survey here.

PensionsEurope welcomes the ECB review of its monetary policy strategy which has undergone a process of gradual transformation since it was adopted in 1998. Today the euro area is facing various new economic challenges, such as the COVID-19 crisis, and there will be many new challenges to overcome in the upcoming years which need to be jointly tackled by monetary, economic, and fiscal policies.

As despite negative interest rates and QE programmes the ECB has not achieved its inflation target over the last years, possibly the ECB could be more flexibility around its inflation target and consider targeting price growth in a band, in full respect of the ECB’s price stability mandate as enshrined in the Treaty.

In general, we believe that unconventional monetary policies have had effect in many areas, including various positive and negative side effects. This applies for the economy at large, as well as for pension funds more specifically in the form of preventing a (severe) recession, realising relatively good returns but also substantially more expensive liabilities. You can read our input to the ECB review of its monetary policy strategy here.

PensionsEurope submitted its response to the ESAs' consultation on their joint draft RTS on ESG disclosures. You can read our response here.

The draft RTS will define the content, methodologies and presentation of disclosures under the Sustainable Finance Disclosure Regulation (SFDR). The most important elements under discussion in the draft RTS relate to the requirements on disclosures of principal adverse impacts (article 4 SFDR) and product pre-contractual disclosures (articles 8 and 9 SFDR).

PensionsEurope recognises there is a need to increase transparency in the field of sustainability risks and sustainable investment opportunities in order to mobilise capital from the financial services sector and foster the green transition. Notwithstanding this, the lack of flexibility of the new disclosure requirements raises concerns as a “one-size fits all” approach does not always reflect market realities and would not fit the information needs of pension funds’ members and beneficiaries.