FESE welcomes and supports the commitment by the European Commission’s as part of the Action Plan on Financing Sustainable Growth to find collective solutions to the urgent threat posed by climate change and considers that initiatives on sustainable finance can complement regulatory actions taken to fight climate change.

A transparent and consistent approach in line with ESG-aspects by the real economy, financial industry and regulators holds great opportunities for the international capital markets, both in the area of risk assessment and for the identification of new business areas. A clearly defined taxonomy, whereby agreement on what constitutes environmentally sustainable assets is found, is a necessary starting point for other actions, such as standards and labels.

Regarding the proposed review of corporate reporting of non-financial information, FESE considers that disclosure obligations on listed issues should be well-calibrated and proportionate. We would caution against increasing non-market-related disclosure obligations on listed issuers alone as this would risk disincentivising companies from listing on public markets, which would not increase transparency.

FESE supports the Commission’s intention to assess short-term market pressure and believes there are several measures that could be taken to incentivise market agents towards long-term orientation.

With respect to the proposal on low carbon and positive carbon impact benchmarks, FESE supports the Commission’s intention, since, while there is currently a spectrum of low carbon benchmarks available to the market, consistently applied, clear definitions would be welcome. However, FESE considers that the proposal, in its current form, lacks clarity, which would facilitate evasion. Moreover, in the context of the Benchmarks Regulation being reviewed, FESE would like to remind policy makers of key concerns regarding the definition of regulated data benchmark that should be addressed.

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