PensionsEurope's response to ESAs' survey on templates for ESG product disclosures

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. Unless the reader is familiar with SFDR, the concepts and explanatory notes used in the illustrative mock-ups are not readily understandable as they directly refer to the definitions set out in the regulation.

The response finally 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. It is not possible to capture all the elements of a multiple ESG investment strategy in a single graphical representation, not even with a few graphical representations, without excessively simplifying the reality.

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