The EBF welcomes the choice of Regulation as the legislative vehicle for delivering these results. Establishing the key definitions that will shape understanding of what is a sustainable economic activity and the steps that should logically follow need to happen within both a global context and the legal framework of an appropriate harmonization process at EU level.
The major issues that RBF would like to highlight are:
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It is essential that the Commission defines and bolsters sustainable finance as part of the Capital Markets Union and takes into consideration banks’ voice given their valuable role in the investment and financing process.
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Commission may have in mind, taking into account the broad definition given to Sustainable Finance in the first place.
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Given the role of banks on sustainable finance, EBF takes the view that the banking sector should be much more involved than has been the case so far in the process of development of the taxonomy, ensuring to include all stakeholders.
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EBF would favour the extension of the scope of the Regulation to cover other sustainability objectives, in particular social objectives from the earliest possible stage subject to the availability of reliable data.
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EBF would also recommend not to commence the work on social (and governance) issues at a too late stage as social issues are also.
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Besides being open to regular updates in response to market evolutions and stakeholders’ needs, the Taxonomy should be open to the possibility of being updated or to abide by a different (and better) set of rules subject to appropriate governance of the validation of such better set of rules. EBF believes that the proposals for regulation should elaborate on existing market practices where possible.
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