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As the main challenges we note the following:
• quality of data: ESG data is not always comparable, reliable or relevant, in certain instances it is not
available
• coherence of legislation: the European Commission should ensure that different existing pieces of
legislation are coherent with imminent legislative initiatives (e.g. the Taxonomy Regulation, Disclosure
Regulation, the upcoming Non-Financial Reporting Directive, …) to avoid duplication of requirements and
ensure smart regulation
• whereas there is sufficient availability of financial capital, there appears to be a lack of eligible projects
Integrating ESG considerations into the financial sector would allow financing the transition to a sustainable
economy. The recent corona virus crisis demonstrated the importance of ESG considerations. It is as ever
instrumental to account for sustainability to make a green recovery and to enhance the resilience of the
economy.
Further to this, we would like to add the following explanation to question 10:
The key matter here is indeed to have a consistent methodology as well as relevant and reliable data. There
are some existing initiatives which could be used as a basis for a common EU-wide methodology. But, to
date, there is no common methodology to estimate temperature scenarios nor a database for such
information. These are prerequisites for temperature portfolio disclosure requirements in order to avoid
misleading results and comparisons. While such estimates on temperature scenarios are desirable, it is
important to note that first of all such estimates have to be technically possible in order to be meaningful.
Nevertheless, any additional data and methodological requirements should build on existing legislation (the
Taxonomy Regulation, the upcoming Non-Financial Reporting Directive, the Disclosure Regulation, …) and
avoid creating an additional burden to institutional investors and credit institutions.