06 November 2020

BETTER FINANCE Response to the European Supervisory Authorities' Survey on templates for Environmental and/or Social financial products unde

We consider that to be comparable, the information disclosed  must reach the highest degree of standardisation at cross-sectoral levels and standardisation concerns not only the type of information to be included, but also the order flow and format; in other words, it must exhibit the same structure. However, we suggest shortening the templates avoiding information overload including complex and misleading information regarding the sub-categories of investments.

General comment

We warmly welcome the the use of specific templates to standardise the disclosures of ESG information. We consider that to be comparable, the information disclosed must reach the highest degree of standardisation at a cross-sectoral levels and standardisation concerns not only the type of information to be included, but also the order flow and format; in other words, it must exhibit the same structure. However, we suggest shortening the templates avoiding information overload including complex and misleading information regarding the sub-categories of investments.

Graphical representation and the use of icons
Icons and visual aids can guide and help the investor to understand complex contents. In addition, the icons and visual images can make the text “lighter” and more intuitive for the investors. Graphical representation could help individual investors to easily understand the sustainable features of the product as long as the same format of graphical representation (for example pie and/or bar chart) is used for the same product category.

Digital media
The use of digital media can be a good opportunity to streamline online KIIDs or KIDs. It would be useful to have different layers disclosing different level of details. In this way, the investor will have a more intuitive and shorter document (at first glance) with an easier access to information.

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