The scope and definitions in the proposal were ALFI’s main concerns.
Indeed, while “sustainability risk” is at the core of the proposal (in last year’s consultation) it was not defined. ALFI is therefore pleased that ESMA has proposed a definition in the current consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD.
Indeed, a definition of “sustainability risk” is key as the concept needs to be defined because all market participants cannot be expected to understand it – at least not in the same manner.
Generally speaking, ALFI agrees with ESMA’s suggestions to integrate sustainability risks and factors in the UCITS Directive and AIFMD through a high-level principle based-approach.
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