The European Banking Federation (EBF) responded to the Joint Consultation Paper on the review of SFDR Delegated Regulation regarding PAI and financial product disclosures. Key points:

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• This is of particular issue in particular for 14 PAI highlighted in our response  that should not be  subject to materiality assessment in the ESRS and  reported mandatorily instead.
• We urge the ESAs to adapt the SFDR Delegated Act to the final ESRS  rules. The SFDR RTS (Regulatory Technical Standard) should allow financial market  participants to use ‘0’ when disclosed by the  corporates under CSRD when data is considered as non material or  to have the possibility to use proxies or estimates for corporates not subject to CSRD.
• It has also  to be recognized that still a large part of the investable companies may not be subject to the CSRD. Without clear guidance it may be difficult to obtain meaningful data on new indicators. Ideally, SFDR indicators should correspond to the information disclosed under ESRS or other mandatory disclosure requirements for companies, to allow financial intermediaries to determine such indicators.
• On the question on safe harbor, allowing companies aligned to the EU Taxonomy to benefit from an “automatic pass” of the SI environmental DNSH would be welcome. However, in light of the difference between DNSH notions in the SFDR and the Taxonomy, we do not see how the “safe-harbor” option would work in practice and how it can be of more than limited assistance in demonstrating compliance with DNSH.