UKSIF response: EU Commission SFDR call for evidence
UKSIF supports the objectives of this call for evidence and would strongly welcome the Sustainable Finance Disclosure Regulation (SFDR) review considering how this framework can be enhanced further to the benefit of financial market participants, investors, and clients across Europe. Please note the 4,000 word character limit for stakeholder responses to the call for evidence.
While the SFDR has elevated consideration of sustainability within financial markets in Europe and more widely, we see a need for the framework to build on its good, initial foundations and transition over time towards a more decision-useful, transparent, and holistic sustainability disclosure and voluntary product classification system. These product categories should reflect an appropriately diverse range of investment approaches to sustainability, broadly aligning where possible with the UK Sustainability Disclosure Requirements (SDR) label categories.
Drawing on our work in the UK’s investment industry in recent years on the FCA’s SDR, we emphasise the need for the review to consider the following areas:
- Putting end investors at the heart of the new SFDR
- Consideration of mutually exclusive product categories
- Interoperability with third-country regimes (e.g. the UK)
- Alignment across sustainable finance initiatives
