ALFI responds to SFDR review consultation by European Commission

20 December 2023 | Statements and Position Papers  


On 19 December 2023, ALFI responded to the European Commission (EC) targeted consultation on the implementation of the Sustainable Finance Disclosure Regulation (SFDR).

In its response, ALFI:

  • suggests targeted improvements to the current SFDR regime. E.g. entity level PAI disclosures should be sufficiently covered under CSRD without additional disclosure requirements under SFDR which only provide little added value to investors.
  • is of the view that product level disclosures should not be expressed on a scale as it would be open to various interpretations, not allowing for sufficient explanation of the relevant ESG approach.

  • advocates for the current SFDR regime to be maintained and, in particular, the current Article 8 and Article 9 SFDR as disclosure regimes. Investors have become accustomed to it and there have been substantial financial and implementation efforts by all financial market participants over the last years.

  • proposes a voluntary labelling regime in addition to SFDR. It may stop the use of articles 8 and 9 as de facto labels and facilitate the understanding of investors, especially retail investors, while still providing flexibility in the investment management approach. E.g. Article 9 – impact, Article 8 - transition. As there could be a variety of ways to potentially structure such labels, ALFI suggests a dedicated consultation in this regard.

Read the ALFI response.