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