Révision du niveau 1 SFDR – propositions de l’AFG

The AFG commented on the consultation launched on 14 September 2023 by the EC regarding the Level 1 review of the SFDR, with a deadline set for 15 December 2023.
As a reminder (see eventid=22926), the main focus of the consultation is on exploring the potential benefits and challenges of introducing a categorisation system for sustainability in financial products, with an emphasis on addressing concerns about greenwashing and market fragmentation while ensuring alignment with existing rules. While the public consultation is addressed to stakeholders who have a more general knowledge of SFDR, the targeted consultation is intended for market participants who have in-depth knowledge and/or (working) experience in the field of sustainable finance disclosure.
The AFG supports the European co-legislators‘ efforts to finance a more sustainable economy, including the SFDR framework, which has been in place for a few years and has shown positive impacts. However, the implementation of the SFDR has raised several challenges and concerns among authorities, financial market participants, and investors. AFG proposes simplifying and ensuring consistency in the sustainable finance regulatory framework, including the transition concept, and putting the final client at the center of the framework. AFG also suggests evolving from a transparency regime to one with minimum criteria based on the strategy and level of ambition of funds.
The organization proposes three categories of products associated with two levels of ambition: 1. Generic focus on Environmental and/or Social objectives, 2. Transition, and 3. Solutions, Impact, and Contribution.
AFG also recommends aligning the clients‘ sustainability preferences questionnaire with these new categories and integrating national labels and strategies equivalent to European Commission’s climate benchmarks into the new framework through an equivalence. The organization continues to work on refining its proposals