ALFI responds to the Joint Consultation Paper concerning taxonomy-related sustainability disclosures

View the ALFI response.

In its response, ALFI made an introductory comment stressing that, given the absence of robust and/or comprehensive data from issuing companies in relation to taxonomy (the new CSRD will enter into force after the SFDR Regulatory Technical Standards will be in place), our association draws the attention of the ESAs to the fact that during a certain transitional period (probably at least one year), financial market participants will lack some data from investee companies to be able to provide a fully-fledged reporting to investors under SFDR and the Taxonomy. On the first question regarding the proposed approach to amend the existing SFDR RTS, while ALFI welcomes the ESA’s proposed approach to amend the existing SFDR RTS, our association further suggests that market participants be offered the option to already start reporting using the draft templates as per this new consultation, as soon as the final report will have been published by the ESAs. The use of the draft templates would in a sense “override” the templates provided in the SFDR RTS.