Réponse de l’AFG à la consultation des Autorités Européennes de Surveillance sur la revue du Règlement Délégué SFDR (niveau 2)

The AFG responded to the consultation by the ESAs on the review of the SFDR Delegated Regulation.
The need for alignment between SFDR and the CSRD is stressed. The need for consistency between ESAs‘ work on SFDR and the EC’s work on CSRD is emphasized. The dependence on data providers in the absence of CSRD coverage for some undertakings is mentioned.
Furthermore, there is a discrepancy in the timing of reporting PAIs, with the ESAs stating that enterprise value is fixed annually while the current value of investments should be considered quarterly.
The importance of addressing distortions in ESG data and ratings providers and creating a holistic regulatory framework is mentioned. The impact of new PAIs on alternative asset classes and the need for an impact analysis on proposed social indicators are discussed. Challenges related to changes in debt profile, company activities, and capital structure are also mentioned. The importance of balanced and consistent treatment of derivatives in the regulatory framework is also emphasized. There is a call for more clarity on indicators before implementation.
The EU’s list of non-cooperative tax jurisdictions is subject to change. The need for clear guidance on the acceptable use of estimates in the absence of reported data is highlighted. The concept of adequate wages and concerns related to the materiality assessment for ESRS standards are raised.
Finally, key point highlighted in the AFG’s response is the need for a clear definition of the „coal sector“ to reconcile financial, risk, and PAI assessments. There are comments on the formula for exposure to the coal sector and the estimation of detention percentage during the year while being consistent with year-end impact figures.