Réponse AFG à la consultation de la Commission Européenne sur la révision du niveau 1 de SFDR

The AFG responded to the EC’s Targeted Consultation on SFDR Implementation. As a reminder, the EC launched a targeted consultation and a public consultation on 14 September 2023 to assess the implementation of the SFDR. The focus of the consultation was directed towards legal certainty, the usability of the regulation, and proposals for enhancing the existing framework. The Commission sought insights into the practical implementation of SFDR, potential shortcomings, and its interaction with other elements of the European sustainable finance framework. The objective was to explore options for improving the overall framework.
The AFG published its response to the consultation, proposing various enhancements to the current framework:
The AFG suggests evolving the existing transparency regime towards a system with minimum criteria, which would help provide clearer guidance and expectations for asset managers.
They also propose linking a fund’s strategy and objectives to a measurable commitment level, ensuring that the categorization under Articles 6, 8, and 9 aligns with the fund’s ambition and sustainability focus.
Instead of using the concept of „sustainable investment,“ the AFG recommends focusing on a “measurable fund engagement“ in sustainable practices. The Sustainable Investment Framework could still serve as an indicator of a fund’s commitment to sustainability.
To ensure consistency and fairness, the AFG calls for equivalence between national labels and strategies equivalent to the EU’s PAB and CTB.
The AFG also proposes simplifying the questions asked in the context of the MiFID II sustainability preferences by aligning them with the product classification and reporting requirements.
In terms of reporting, the AFG recommends implementing a single reporting template for all products, which would streamline the process and make it easier for investors to compare funds.
Lastly, the AFG suggests a simplified entity-level reporting that includes only relevant and cross-sectoral PAI indicators, which would reduce the reporting burden on asset managers while still providing valuable insights for investors.