GBIC comments on Review of SFDR Delegated Regulation regarding PAI and financial product disclosure

05 July 2023

GBIC fully supports the EU Action Plan on financing sustainable growth. Our associated members (Banks/Savings Banks) are committed to contributing to the goal of reorienting capital flows towards sustainable investments by developing investment strategies and issuing products that serve different sustainability preferences of clients.

In this context the banks have made a considerable effort to implement the disclosure obligations under the SFDR. The market for sustainable investments is experiencing a rapid growth in Germany and the industry is actively taking part in the evolution of the regulatory frameworks to ensure that they will create an environment in which sustainable investing can thrive and grow.
Against this background, we welcome the opportunity to comment on the ESA joint consultation paper on the review of SFDR Delegated Regulation regarding PAI and financial product disclosures, even if it is questionable whether fundamental changes regarding PAI disclosures and the templates make sense at this point in time. We hope that by reviewing the material concepts of SFDR and providing new proposals in terms of investor information on PAI and the ESG templates, the results of the ESAs’ work will contribute to the EU framework for sustainable finance...

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