Insurance Europe has prepared an overview of the requirements that emerge from the Sustainable Finance Disclosure Regulation (SFDR). Significant work is pending at level 2, and ESAs are currently developing proposals. Insurance Europe is seeking members’ support in identifying potential proactive points for engagement. In fact, the EC asked Insurance Europe to identify the most problematic implementation issues, with the objective to put pressure on the ESAs to deliver feasible solutions via its Level 2 work.
Members are kindly invited to share with companies in national markets:
- the summary of the requirements to be implemented according to the Sustainable Finance Disclosure Regulation (SFDR), based on Insurance Europe analysis (Insurance Europe Overview of requirements in the EU regulation on sustainability disclosures.pdf).
- the Insurance Europe questionnaire on compliance with the SFDR (Insurance Europe Questionnaire on the EU regulation on sustainability disclosures.pdf) – which is meant to help Insurance Europe identify potential proactive ways to engage with the ESAs in their upcoming work.
Input should be sent to investments@insuranceeurope.eu before 22 January 2019 cob.
Background
Following the signature of the legal text by the EP and Council on 27 November, the SFDR is expected to be published in the OJEU in December. It will enter into force on the twentieth day following that of its publication and apply after 15 months from that date.
The ESAs need to develop a number of draft RTS in the coming months. A consultation on the Level 2 measures is expected in Q1 2020 (March tbc).
On 5 November, Insurance Europe and other financial trade associations met with the EC (DG FISMA) to discuss the SFDR. At the meeting, Insurance Europe highlighted the challenges of complying with the timetable and explained the importance of taking into account the implementation challenges ahead to avoid legal uncertainties detrimental to financial market participants, advisors and consumers. Insurance Europe also noted that sustainability disclosures need to consider the existing issues with ESG data required to comply with the proposed measures.
The EC acknowledged potential operational and compliance issues that the financial market players will face in the implementation of the requirements. The EC appreciated the constructive approach of the industry to support the implementation efforts and asked detailed questions on the most problematic implementation issues, with the objective to put pressure on the ESAs to deliver feasible solutions via its Level 2 work.