Sustainability-related disclosures in the financial services sector (SFDR) and key information documents for packaged retail and insurance-based investment products (PRIIPs)

Iceberg Data Lab (IDL), as an environmental data provider working closely with investors and financial institutions on sustainability analysis and regulatory reporting, welcomes the Commissions review of the Sustainable Finance Disclosure Regulation (SFDR).

The CEZ Group strongly believes the revision of the Sustainable Finance Disclosure Regulation should be in line with the decarbonisation policy objectives and support transition path of energy companies, which strive to lower the carbon footprint.

Inverco supports that the sustainability perspective of investment advisory services and discretionary portfolio management services should fall outside the scope of the SFDR. As investment services, and in the interest of greater simplification and consistency within the regulatory framework, this should be fully addressed under MiFID.

On behalf of Franklin Templeton We applaud the direction of the Commissions proposal, subject to a few important recalibrations. EFAMA has recently produced an SFDR paper which we support, but we would highlight the below points. Sovereign Bonds: Sovereigns play an important part in the decarbonisation of society and their bonds should be eligible for inclusion in Art.7 funds.

FBF Summary Position on the European Commissions proposed SFDR 2.0 Regulation A more detailed version of this response is attached The FBF welcomes the European Commissions proposed revision of the SFDR (SFDR 2.0), noting substantial simplification, clearer terminology and more meaningful product categories.

Mirova supports the European Commissions proposal to revise the SFDR, which represents a critical step in strengthening the credibility and long term stability of the EU sustainable finance framework. Mirova highlights the following key points requiring the legislators attention.

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR), Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs) and…

BETTER FINANCE welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) and the move towards a clearer product categorisation framework. This is an important step towards improving legal certainty, limiting greenwashing and helping retail investors better understand the sustainability profile of financial products.

CCOO is the leading trade union in Spain in terms of number of members and delegates elected in union elections. CCOO is structured into Federations, according to the activity or sector to which the company belongs, and Unions, according to the territory where the workplace is located. CCOO participates in the governance of occupational pension plans through the supervisory boards of occupational pension funds.

AMICE welcomes the European Commission's initiative to review and simplify the Sustainable Finance Disclosure Regulation (SFDR). The overall objectives of improving legal clarity, enhancing consumer understanding and refocusing the framework on product-level disclosures are broadly supported.

Lazard Frères Gestion welcomes the European Commissions initiative to review the Level 1 framework of the SFDR. 1. Support for Key Simplifications Overall, we view several elements of the proposed evolution positively, moving towards greater clarity, comparability, and credibility for investors. We support the suppression of the notion of sustainable investment.

We are pleased to share our position paper on the SFDR 2.0 proposal, focusing on the role and treatment of impact investing within the evolving EU sustainable finance framework. The paper outlines key conceptual and practical challenges in the current draft and provides targeted recommendations to strengthen clarity, consistency, and credibility in the regulation.

The initiative aims at reviewing EU rules on sustainable finance disclosure with the objective of simplifying the framework, enhancing its usability and preventing greenwashing. It is therefore necessary to limit and disclose the risks of derivatives by allowing exit and repayment that guarantees at least the capital invested.

Filed in Italian · English published by the European Commission

Bundesverband Alternative Investments e.V. (BAI) welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) and supports the overarching objective of creating a clearer, more focused, and more practicable disclosure framework.

These submissions provide recommendations based on ClientEarths experience working to tackle greenwashing in the financial sector using the law. We do not comment on all aspects of the SFDR proposal or make detailed proposals as to the shape of a revised SFDR framework. Instead, we focus primarily on the proposed fossil fuel exclusions as a key element in achieving the objectives of the SFDR reform.

The SFDR proposal contains two major insurance-specific considerations are of particular importance to Insurance Sweden; the treatment of traditional life insurance products and multi-option products (MOPs). Swedish insurance and pension providers manage about EUR 700 billion, representing approximately 5% of the EU insurance and occupational pension market.

Amundi believes that the European Commission (EC)s proposed revision of the Sustainable Finance Disclosure Regulation (SFDR) constitutes a resolute first step in the right direction. We commend the introduction of a simple and clear categorisation system for ESG financial products & the inclusion of restrictions on uncategorised products with regard to the mention of the consideration of sustainability factors or…

The International Transport Workers Federation (ITF) is a global trade union federation representing transport workers across maritime, aviation, rail, road, ports, and logistics. With more than 700 affiliated unions in over 150 countries, the ITF represents approximately 20 million workers essential to global supply chains and the real economy.

FEBEA welcomes the Commission's proposal as a concrete step toward and endorses several of its key innovations, including the shift to a categorisation regime, the recognition of impact investing, and the stricter treatment of fossil fuels. Building on this positive foundation, FEBEA calls on co-legislators to ensure that the social dimension receives equivalent operational treatment to the environmental one.

MAIF welcomes the European Commissions proposed revision of the Sustainable Finance Disclosure Regulation (SFDR), a key tool to enhance transparency, guide consumer choices, and drive capital toward sustainable investments. To preserve this ambition, MAIF highlights four priorities: 1.

The European Commissions proposal reflects the genuine effort to address shortcomings identified during the first years of implementation, and several elements are particularly welcome for AXA, such as: (i) the removal of entity-level disclosures eliminating overlaps with the CSRD; (ii) the reduction of product disclosures to a concise two-page format; (iii) the principle of non-gold-plating (art.

Ofi Invest AM welcomes the core ambition of the reshaping of SFDR to enhance the clarity and coherence of sustainable finance in Europe. We fully support the objective of harmonising practices at the European level by replacing divergent national frameworks, thereby ensuring a consistent regulatory environment for all stakeholders.

LBP AM warmly welcomes the proposal to switch from a transparency approach to a mandatory categories approach for responsible products. LBP AM also strongly supports the proposed categories, which should create meaningful classifications investors while covering the variety of approaches available on the market.

French Asset Management Association (AFG) supports the efforts of European co-legislators towards financing a more sustainable economy and the review of the SFDR. The proposed revision is a first step in the right direction. It addresses a widely shared need in the industry: to simplify and clarify ESG product categories so that investors can finally make sense of them.

We support the simplification of the SFDR to improve clarity and integration with the sustainable finance framework. At the same time, it is essential that the unique characteristics of the insurance sector are addressed in the forthcoming negotiations. Please find our detailed recommendations attached.

Forvis Mazars provide audit & assurance, tax, advisory and consulting services in over 100 countries and territories, including 26 European member states. Forvis Mazars provide a comprehensive assessment of the Commissions proposal to revise the Sustainable Finance Disclosure Regulation, highlighting key shortcomings of the current framework and recommending targeted improvements to enhance its effectiveness.

As a citizen bank and a purpose-led company committed to a just transition, La Banque Postale (LBP) reiterates its support for the European Commissions ambition regarding sustainability and the environmental transition, which requires the development of a clear, coherent and operational regulatory framework for the financial sector.

France Assureurs supports the overall architecture of the proposed revision of the SFDR regulation and its objectives of enhancing the clarity of financial product categories and strengthening the credibility of the EU sustainable finance framework.

We welcome the European Commissions SFDR 2.0 proposal and its effort to improve clarity for investors, simplify the framework, and enhance consistency with MiFID/IDD and other sustainable-finance regulations. With targeted adjustments, it has the potential to better support the EU transition while remaining workable for investors.

FECIF welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR), considering it a necessary and timely response to the shortcomings of the current framework. The revision rightly aims to improve investor understanding, simplify disclosures, and reduce administrative burdens, while restoring clarity in the sustainable finance market.

Confindustria Assoimmobiliare considers the revision of the SFDR an important step in strengthening the EU sustainable finance framework. However, the proposed changes significantly reshape product categorisation and disclosure requirements and require further clarification to ensure proportionality, workability and consistent implementation.

Overall, ShareAction welcomes the European Commission's proposed revision of the SFDR. The proposal represents a meaningful step towards a clearer and more accessible framework for retail investors and consumers, and the introduction of a formal product categorisation system is a welcome improvement that addresses longstanding concerns around the misuse of Article 8 and Article 9 classifications as de facto…

EXCUTIVE SUMMARY The European Commission's new SFDR proposal is pragmatic, striking a commendable balance between prescriptiveness and flexibility. The three categories ("ESG basic," "transition," "sustainable") represent more marketable terminology, though their contents require clarification and the French translation of "ESG basic" warrants consumer testing.

In the context of the ongoing review of the Sustainable Finance Disclosure Regulation (SFDR), we would like to express our strong support for the European Commissions proposal to explicitly recognise impact investing within the revised framework. This recognition constitutes a major milestone for the European sustainable finance ecosystem.

This position paper outlines (i) the elements European Development Finance Institutions (EDFI) who comprise the EDFI Association support and (ii) the key adjustments required to ensure SFDR 2.0 truly becomes a practical, globally applicable and transition-enabling framework capable of supporting high-impact investment in EMDE markets.

The Institut de la Finance Durable welcomes the proposed revision of the SFDR by the European Commission, while calling for targeted adjustments to enhance its coherence, clarity, and effectiveness. In particular, we advocate for a broader and more consistent scope that includes all financial products incorporating sustainability features.

Deutsche Börse Group (DBG) welcomes the European Commissions proposal to amend the Sustainable Finance Disclosure Regulation (SFDR). The SFDR has been instrumental in enhancing transparency in sustainable finance, but its implementation has also revealed significant challenges, including legal uncertainty and undue complexity, which have hindered its effectiveness and created burdens for market participants.

ZIA represents nearly 40 AIFMs managing real estate and infrastructure funds with assets under management in the hundreds of billions. While ZIA has supported the SFDR's approach of mobilizing private capital for sustainable investments from the outset, the current framework has created inconsistencies, excessive bureaucracy, and reporting burdens.

Eurelectric supports the Commissions work to enhance the usability of the Sustainable Finance Disclosure Regulation (SFDR). Towards this end, we wish to contribute targeted recommendations to improve the new SFDR proposal.

CNP Assurances welcomes the opportunity to contribute to the Commissions consultation on the revision of the Sustainable Finance Disclosure Regulation (SFDR). CNP Assurances fully supports the objectives pursued by the revision of SFDR, which aims to simplify the existing framework, improve its effectiveness, enhance investor protection and reduce greenwashing risks, notably through the replacement of Articles 8 and…

We welcome the European Commissions initiative to revise the SFDR and its efforts to improve the transparency, usability, and comparability of sustainability-related information in financial products. The proposed introduction of clearer product categories represents an important step toward addressing shortcomings in the current disclosure-focused framework and improving alignment between financial products and…

Credit Agricole Group welcomes the review of the Sustainable finance disclosure regulation (SFDR) and supports the Commission efforts to simplify the framework. The objective of SFDR, whether in its version 1 or version 2, is to promote the channeling of investments and household savings towards sustainable projects, so that such projects can be realized.

The Sustainable Finance Disclosure Regulation (SFDR) is a key part of the EU sustainable finance framework. It has improved transparency on sustainability-related issues in financial markets. However, although it was designed as a disclosure regime, it has been used in practice as a product classification system. This has created implementation challenges and inconsistent interpretation.

Unipol Group welcomes the European Commissions initiative to review the Sustainable Finance Disclosure Regulation (SFDR) and broadly supports the overall direction and objectives of the proposed reform. We support the objective of enhancing transparency, reducing greenwashing risks, and improving the usability and effectiveness of sustainability disclosures for investors.

WWF welcomes the Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR), which is a necessary step to move towards a more credible, transparent and operational framework. We particularly welcome (1) the establishment of a clear categorisation system, with specific criteria and requirements, (2) robust fossil fuel expansion exclusions in the Sustainable and Transition category, and (3)…

The review of the Sustainable Finance Disclosure Regulation (SFDR) is a positive step to bring much-needed clarity to what can be considered a sustainable finance product. The creation of product categories with minimum criteria is a key change that is needed to limit greenwashing that can mislead consumers.

The European Association of Cooperative Banks (EACB) welcomes the review of the Sustainable Finance Disclosure Regulation (SFDR) and supports the Commissions efforts to simplify the framework by reducing product level disclosures, removing certain obligations and streamlining reporting. These improvements are positive, yet several elements require clarification to ensure legal certainty and workable implementation.

In line with DVFAs mission to promote the highest standards of professional conduct among its members and to strengthen the role of capital markets by fostering trust and integrity, DVFA supports an effective sustainable finance regulation.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) as a significant and much-needed step forward for the EU sustainable finance framework.

Assoreti - the Italian Association of intermediaries which provide investment advice services through their financial advisors authorised to operate off-premises (tied agents who are natural persons) - would like to thank you for giving it the chance to contribute to the SFDR revision.

The LSFI Impact Investing Advisory Board (IIAB) welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) and, in particular, the explicit recognition of impact investing within the framework.

The Dutch Banking Association appreciates the opportunity to contribute feedback on the proposed regulation regarding sustainable finance disclosure. Below, we highlight our main points. For our detailed feedback on the proposal regulation we refer to our position paper attached to this response.

Bank im Bistum Essen is an active member of the Social Investor Working Group (SIWG). The SIWG, coordinated by SPTF Europe asbl, is a network of investors in emerging markets. The SIWG advocates for embracing interoperability, recognising the diversity of global investment contexts, and enabling proportionate disclosures that empower not penalise those who lead on inclusive and sustainable investment practices.

We welcome the ECs review of the SFDR and support its objective of simplification, with a renewed focus on products and retail investors. Our position is grounded in market experience and direct feedback from clients across Europe. The introduction of a three-category product framework offers an opportunity to improve decision-useful disclosures and enhance comparability.

The SIWG, coordinated by SPTF Europe asbl, is a network of investors in emerging markets. The SIWG advocates for embracing interoperability, recognising the diversity of global investment contexts, and enabling proportionate disclosures that empower not penalise those who lead on inclusive and sustainable investment practices.

WeeFin, an impact fintech aiming to raise sustainable finance standards, welcomes the European Commissions proposal to revise SFDR. Positioned at the intersection of asset owners, asset managers, insurers, and data providers, WeeFin has a practical understanding of the challenges linked to implementing sustainable finance regulations.

This response from the Association of Real Estate Funds (AREF) has been based upon a joint model response drawn up by the European Investors in Non-LISTED Real Estate (INREV) with collaboration from real estate related associations across Europe. Members of the British Property Federation (BPF) have also contributed to AREFs response.

Joint feedback to the EC on the SFDR Revision by the voluntary sustainability-related labels: FNG-Label, LuxFLAG, Nordic Swan Ecolabel and Towards Sustainability. Targeted contribution on inclusion of voluntary sustainability labels in the Sustainable Finance Disclosure Regulation (SFDR 2.0) reporting templates The revision of the Sustainable Finance Disclosure Regulation (SFDR) under the SFDR 2.0 legislative…

In general terms, we consider that the proposal goes beyond the mere simplification of rules and, in several areas, moves closer to deregulation of the current framework, with potential risks in terms of reduced transparency and increased greenwashing. At the same time, we also recognise some positive elements, which are reflected in the comments below: 1.

As the European Union (EU) advances the revision of the Sustainable Finance Disclosure Regulation (SFDR), the Global Legal Entity Identifier Foundation (GLEIF) welcomes the proposal to retain the requirement for financial market participants that are legal persons to obtain a Legal Entity Identifier (LEI), as set out in Commission Delegated Regulation (EU) 2022/1288.

The German Banking Industry Committee welcomes the Commissions proposal, which is aimed at further developing the SFDR to make it a more coherent, user-friendly and effective framework. The introduction of three product categories with relevant requirements improves the current regime. The simplification of disclosure requirements (e.g.

Insurance Europe welcomes the opportunity to provide comments and our detailed feedback can be found attached. Insurers remain fully committed to the EUs sustainability agenda and to financing the green transition. However, experience with the current framework shows that complexity, legal uncertainty and frequent supervisory updates have limited its effectiveness.

ESBG welcomes SFDR 2.0 proposal and supports the shift from a disclosure-only approach to clearer product categories. We support removing individual portfolio management and financial advice from scope and welcome the reduction of entity-level disclosures (incl.

ANIA, the Italian Insurance Association, deems important to revise the SFDR framework in order to render it more effective to promote sustainable finance, while simplifying it in the interest both of financial market participants and of their clients.

German Insurers strongly support simplifying the current SFDR to restore its function as a customer disclosure tool. The significant simplifications introduced by the Commissions proposal are therefore a positive step, although the introduction of a categorisation system comes along with new challenges.

SIFA is broadly supportive of the Commissions proposal to revise the SFDR. The proposed shift towards a more product-oriented framework, a clearer scope limited to financial products, and more proportionate disclosure requirements is welcome. These changes better reflect how SFDR is applied in practice and have the potential to improve comparability and usability for investors.

Finance Denmark supports the Commissions proposal, which contains several positive elements. We welcome a revision that strengthens the focus on investor understanding and improves the usability of sustainability information.

F2i welcomes the European Commissions proposal for the revision of the Sustainable Finance Disclosure Regulation (SFDR). Alongside positive elements, F2i considers that certain aspects would benefit from further clarification or adjustment to ensure legal certainty, proportionality and coherence within the broader EU sustainable finance framework, in particular: 1.

ALFI supports the European Commissions (EC) ambition to simplify the SFDR framework by reducing administrative requirements, improving clarity for end investors and strengthening the frameworks coherence. We welcome in particular: - The exemption for funds closed before the application date of SFDR 2.0. - In principal, the establishment of three main distinct categories.

Please see attached file which outlines Insurance & Pension Denmarks key messages on the proposed changes to the SFDR. Insurance & Pension Denmarks remains at your disposal for further elaboration of our messages and for input on how to concretely work out improvements to the SFDR.

We agree with the importance of revising the current framework on sustainability-related disclosure in financial services (SFDR) in order to effectively simplify the current disclosure requirements and to address the various shortcomings with the interpretation and implementation of the current requirements.

EFPA welcomes the European Commissions proposal to revise the SFDR, considering it a positive step toward enhancing clarity, usability, and comparability for financial advisers and retail investors. The introduction of three voluntary product categoriesSustainable, Transition, and ESG Basicsis strongly supported, as it can improve investor understanding and address confusion linked to the current use of Articles 8…

The revision of the SFDR comes at a key moment for European sustainable finance. The FIR welcomes the clarification and simplification of products and the introduction of a transition category, which is a structural step forward.

Filed in French · English published by the European Commission

We welcome the review of the Sustainable Finance Disclosure Regulation (SFDR). However, we believe that further refinement of the SFDR is necessary to fully reap the benefits of the revision and unlock the potential for sustainable investing. Deutsches Aktieninstitut suggests (1) to adopt a slim set of decision-useful PAI-indicators for product-level reporting, grounded in the same datapoints as used in ESRS 2.

The current SFDR framework has become overly complex, costly and challenging for investors to navigate. While the European Commissions 20 November 2025 proposal moves in the right direction, it still requires clearer and more operational product category criteria, tighter alignment with CSRD/ESRS and the EU Taxonomy, and a radical simplification of disclosures.

The DIHR welcomes the amendment of the SFDR as an opportunity to consolidate the human rights/social sustainability dimension of this regulation. The DIHR's recommendations for the SFDR review (see briefing attached) seek to facilitate policy coherence with related EU sustainable finance and corporate sustainability instruments as well as coherence with international standards on responsible business conduct…

Irish Funds welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) and broadly supports the direction of travel under the proposed SFDR 2.0 (Proposal). Certain aspects of the Proposal are particularly welcome, as they represent practical improvements to the current framework.

The Swiss Finance Council (SFC) strongly supports efforts to build an effective framework for sustainable finance to facilitate the transition to a sustainable economy, and we credit the EU for its leadership in the sustainable finance space.

The Association for Financial Markets in Europe (AFME) and the International Swaps and Derivatives Association (ISDA) (together, the Associations) welcome the European Commissions proposed revision to the Sustainable Finance Disclosure Regulation (SFDR 2.0). The proposal represents important progress towards achieving the original policy objectives of the SFDR.

Febelfin, the Belgian Financial Sector Federation, endorses the position paper submitted by the European Banking Federation (EBF) on the SFDR Revision Proposal and calls on co-legislators to consider the EBFs recommended amendments. We share the EBFs overall positive assessment of the Commissions proposal and support its key recommendations.

PGIM supports the European Commissions initiative to revise the Sustainable Finance Disclosure Regulation (SFDR) and views the proposed changes as an important step in strengthening the EU sustainable finance framework.

The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) represents the European non-listed real estate investment industry. INREV supports the development of professional standards, transparency and best practice across the sector through research, industry guidance and policy engagement.

The Forum Nachhaltige Geldanlagen (FNG) welcomes the initiative to introduce a categorisation system with clear thresholds. We support a core set of minimum exclusions and call for sovereign bonds as well as cash to not be included at all in the calculation of the 70% threshold. We urge Parliament and Council to reconsider the removal of the definition of sustainable investment.

PensionsEurope supports the European Commissions objective to simplify SFDR 2.0, but cautions that the proposed categorisation system is structurally misaligned with occupational pensions. Unlike retail product manufacturers, Institutions for Occupational Retirement Provision (IORPs) are long-term institutional investors and customers of financial products, operating under fiduciary duty and liability-driven…

The European Banking Federation strongly supports the European Commissions efforts to reduce the complexity of sustainability-related disclosures for capital markets and increase their usability for both investors and financial market participants.

Finance Watch welcomes the Commissions proposal for a revision of the SFDR. Minimum criteria for the SFDR product categories, the distinction between transition and sustainable investments, and improvements in the clarity of sustainability disclosures will support the transparency and the understandability of the framework for retail investors.

The CNMV's Advisory Committee has been set by the Spanish Securities Markets Law as the consultative body of the CNMV. It is composed by market participants, and its opinions are independent from those of the CNMV.

European Commission Consultation on the Proposal to Amend the Sustainable Finance Disclosure Regulation (SFDR) Response from the Association des Banques et Banquiers, Luxembourg (ABBL). The Association des Banques et Banquiers, Luxembourg (ABBL) welcomes the opportunity to comment on the European Commissions proposal (COM(2025)841) to amend Regulation (EU) 2019/2088 on sustainability-related disclosures in the…

The European Public Real Estate Association (EPRA) represents Europes listed real estate sector and has served for 25 years as the key voice of listed property companies, investors, and service providers. With over 290 members and more than 930 billion in European real estate assets, EPRA promotes transparency, best practices, and a stable and competitive regulatory environment for listed real estate.

We support any development that simplifies the nomenclature of products offered to investors and savers and improves their understanding. It is essential to facilitate the approach and acceptance of the end investor, who is currently sometimes resistant due to the perceived complexity and imprecision of the existing nomenclature, even as companies offering these products struggle to comply with it and risk being…

Overall, the CNMV welcomes the changes proposed by the European Commission. In particular, it supports the introduction of three product categories sustainable, transition and ESG as well as the removal of the sustainable investment concept (Article 2(17)) and entity-level disclosure requirements.

BVI welcomes the EU reform of the SFDR framework and applauds the EU Commission for bringing forward a proposal that is considerate of both, safeguarding ambition of ESG-related investment strategies and the need for ensuring continuity and building upon approaches and standards already implemented in the market.

Axylia welcomes the reform of the SFDR proposed by the European Commission as a necessary move towards a more readable and operational framework. The introduction of clearer product categories, replacing Articles 8 and 9, addresses the difficulties observed since the entry into application of the Regulation. The recognition of transition strategies better reflects the reality of decarbonisation pathways.

Filed in French · English published by the European Commission

The current European sustainable finance framework is quite broad and consists of multiple legislative instruments. In this context, it is argued that the revision of the SFDR should be properly linked to the necessary adaptation of other relevant legislation, such as the framework of the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive (IDD), in particular with regard…

Filed in Portuguese · English published by the European Commission

Overall, IIGCC welcomes the Commission's proposed revisions of the SFDR. The proposals account for feedback from financial market participants, better recognise the critical role of transition-related investment strategies, and addressing implementation issues.

Mr LASPIM supported the review of this Regulation and in particular the creation of a transition category more suited to the current furniture renovation process. However, ASPIM has identified with its members a number of datory points for unquoted real estate funds.

Filed in French · English published by the European Commission

The European Commissions proposal for SFDR 2 represents a significant advancement towards a harmonised single market for sustainable investment products in Europe. The move to clearer product categories, defined by investment strategy and end investor objectives, promises to ease product navigation for retail investors, align disclosure requirements, and foster greater confidence in the EU sustainable finance…

The Sustainable Banking Coalition (SBC), representing fossil fuel-free, environmental, and social sustainability-focused financial institutions across the European Union (EU), recognises the European Commission's initiative to revise the Sustainable Finance Disclosure Regulation (SFDR) as a critical opportunity to strengthen Europe's sustainable finance framework.

We welcome the review of the Sustainable Finance Disclosure Regulation (SFDR) as an essential opportunity to address persistent greenwashing and restore investor confidence in EU sustainable finance. Since its adoption, SFDR has suffered from unclear interpretations of Articles 8 and 9, leading to frequent fund reclassifications and significant confusion for investors.

The revised SFDR provides for an exclusion for all three types of sustainabel funds of "violations of the United Nations Global Compact (UNGC) principles or the Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises (OECD MNEs)," We would ask you to specify that this exclusion follows the Note published in July 2011 by the The UN Global Compact on the Relationship…

The Sustainable Finance Disclosure Regulation (SFDR) adopted in 2019 triggered a vast movement of self labelling by asset managers. Intended as a classification that would put some order in the European Union sustainable funds market, SFDRs articles 8 and 9 quickly became a source of confusion.

e-MFP and Cerise+SPTF, financial inclusion networks representing social- and impact-finance actors investing in emerging markets, welcome the revision of the Sustainable Finance Disclosure Regulation (SFDR). We view SFDR 2.0 as an opportunity for the EU to both strengthen internal market competitiveness and build a global safe harbour for capital that pursues environmental and social impact alongside financial…

The ESRS include a number of datapoints that reference SFDR social indicators so that financial market participants are able to comply with SFDR by relying on public data reported by real economy companies in line with the CSRD.

Executive summary The following shortcomings within the EU Taxonomy framework translate in low and unreliable EU Taxonomy eligibility and alignment numbers: Complex and overly ambitious technical screening criteria (TSC) Unclear and ambiguous concepts, leading to uneven reporting practices Inadequate transition perspective EU Taxonomy figures should not therefore be considered as a metric to measure the…

ClientEarth's response offers reflections and recommendations based on our experience working to tackle greenwashing in the financial sector using the law. We make no attempt to comment on all aspects of the SFDR review or make detailed or comprehensive proposals as to the shape of a revised SFDR framework. We believe these comments to be relevant regardless of the precise shape of the revised SFDR framework.

## EU Commission Consultation Response ### *Submitted by 1Horizon Foundation May 2025* > In response to the European Commission's Call for Evidence on the impact assessment of the SFDR revision, 1Horizon proposes a next-generation disclosure and impact framework designed to align sustainable finance with planetary boundaries, regenerative economics, and collective intelligence. > --- ### Executive Summary 1.

As a pioneering company in sustainable finance, Mirova has been a staunch advocate and architect of the European Commission's Action Plan for Sustainable Finance since 2018. We remain firmly convinced that all initiatives derived from the previous Green Deal and its transparency standards are essential levers for transforming our economies and ensuring a just transition toward sustainable activities and practices.

NorthPeak Advisory welcomes the opportunity to respond to the European Commissions (EC) Call for Evidence relating to the Sustainable Finance Disclosure Regulation (SFDR). NorthPeak Advisory was founded in 2020 with the mission of helping asset managers, asset owners, and corporates navigate the rapidly evolving sustainability landscape.

InfluenceMap welcomes the opportunity to contribute to the upcoming review of SFDR. In December 2024, InfluenceMap released the report EU Funds: Has Regulation Impacted Climate Performance?, a climate assessment of 17,529 EU-domiciled funds subject to SFDR and the ESMA fund naming guidelines.

We thank the European Commission (EC) for the opportunity to participate in its call for evidence on the review of the SFDR and welcome the ECs ambition to simplify and streamline the SFDR. There remain diverging views in the market, however, as SFDR has contributed to increased transparency, investors have become accustomed to the current regime and financial market participants (FMPs) have invested substantial…

The Institut de la Finance Durable (IFD) supports the orientations proposed by the European Commission in its call for evidence on the SFDR revision. These orientations are consistent with the positions previously expressed by IFD, especially in its response to the targeted consultation on the implementation of SFDR of December 2023, and in its joint position with Paris Europlace published in May 2025 on the…

BETTER FINANCE welcomes the European Commissions plan to revise the SFDR to fix its complexity, legal gaps, and greenwashing risks. As the voice of EU citizens as financial services users, we back a clearer, simpler, and more effective framework that helps individual investors make informed sustainable investment decisions.

Insight Investment is one of the largest investment managers in the UK, managing £626bn in assets , primarily for UK pension funds, as well as insurers, sovereign wealth funds and financial institutions. Insight welcomes the European Commission (EC)s call for evidence for an impact assessment on the Sustainable Finance Disclosure Regulation (SFDR) review.

An in-dept SFDR review presents significant business opportunities, as scaling up sustainable finance equates to scaling up overall finance. It should incentivize asset managers and insurers to launch products while encouraging clients to invest. It would be beneficial to include structured products in SFDR if the revised regulation is effectively designed.

MAIF welcomes the European Commissions consultation on the revision of the SFDR, a key regulation for promoting transparency in sustainable finance. By empowering consumers and guiding capital towards responsible investments, the SFDR plays a vital role in supporting the transition to a fair, environmentally respectful, and biodiversity-friendly economy.

On behalf of the pan-European private equity and venture capital (PE/VC) industry, weve set out below our comments on the future direction of SFDR. The attached comprehensive response contains further technical details and supporting arguments. Please also refer to our previous letters to the Commission from 30/01 and 16/05/2025.

AIFI, the Italian private equity, venture capital and private debt association, thanks the European Commission for the possibility to provide feedback on the revision of EU Regulation 2019/2088 (Sustainable Financial Disclosure Regulation SFDR). Attached you can find a document with the main elements that, according to us, should be taken into account in reviewing the Regulation.

SFDR is a major regulation for BNP Paribas Asset Management with over 90% of assets in our open-ended EU funds classified as Article 8 or 9. While SFDR has clearly contributed to reallocation of capital towards a more sustainable economy, the current framework has shortcomings that need to be addressed.

We identify several matters that could enhance the usefulness of the information provided under SFDR and the effectiveness of implementation, and reduce its complexity in line with its ultimate objective to enhance the transparency of sustainability information for the end investor. For details please see the attachment. 1. Reduce the complexity and administrative burden of the PAI statement at entity level.

This is Niche AM feedback (check https://nicheam.com/newsletter-en/): 1) AIM OF THE REGULATION. Sustainability regulation is an essential tool for risk management not for improving the world. This is a side effect.

Deka Investment is the asset manager within the German Savings Banks Finance Group. With a broad portfolio of products that disclose under Art. 8/9 of SFDR the SFDR plays a central role in our sustainable finance framework, and we welcome the opportunity to share our main remarks to the review of the SFDR: 1.

The SFDR has introduced several benefits, especially in terms of transparency. However, it has yet to fully realise its potential in strengthening investor protection and steering capital toward sustainable activities. For us, the much-needed amendments in the revision of SFDR provide a good opportunity to meet the Regulations intended objectives.

As a representative of banking sector, we would like to present the postulates which are the presentation of the holistic perspective of banks, where different regulations with reference to the sustainable elements meet.

Our key recommendations towards a simple, clear and comparable system for all investors to shift capital to a sustainable economy 1. Enhance Clarity and Comparability Implement a grading system (1-5) applicable to all financial products to allow for easy comparison, eliminating distinctions between sustainable and non-sustainable products.

Assoreti Association of intermediaries which provide investment advice service through their network of qualified financial advisors is grateful to the European Commission for the opportunity given to hear its views on the Revision of EU rules on sustainable finance disclosure (SFDR).

At WeeFin, we advocate for a reform of the SFDR regulation. It is clear that this regulatory framework has not achieved its initial objectives of transparency, education, comparability between funds, and the fight against greenwashing.

e-MFP and Cerise+SPTF, financial inclusion networks representing social- and impact-finance actors investing in emerging markets, welcome the revision of the Sustainable Finance Disclosure Regulation (SFDR). We view SFDR 2.0 as an opportunity for the EU to both strengthen internal market competitiveness and build a global safe harbour for capital that pursues environmental and social impact alongside financial…

The summary of ESG Book's recommendations is as follows: (Detailed recommendations and research are available in the document) 1. Stronger integration with CSRD, Taxonomy data, and frameworks for financial institutions 2. Enhanced usability through simplified formats and digital alignment 3. Revision of Principal Adverse Impacts (PAIs) in alignment with ESRS with clear guidance and thresholds 4.

MSCI welcomes the opportunity to respond to the European Commissions Call for Evidence on the Sustainable Finance Disclosure Regulation (SFDR). The points set out below summarise our principal recommendations, while detailed technical observations are included in the annex to this submission. 1.

F2i SGR is Italy's largest independent infrastructure asset manager, with over 8 billion euros under management across sectors critical to the EU's sustainability agenda. Based on its operational experience in sustainable finance, F2i welcomes the opportunity to contribute to the review of the SFDR. F2i recognises that the SFDR has played a central role in enhancing transparency in sustainable finance.

The Towards Sustainability Labelling Agency (CLA), the body responsible for the "Towards Sustainability" label a leading independent standard for sustainable financial products in Europe welcomes the SFDR review.

The European Federation of Financial Advisers and Financial Intermediaries (FECIF), representing over 300,000 financial professionals, 30 million clients, and 3 trillion in investable assets across the EU and EEA, welcomes the European Commissions initiative to revise the Sustainable Finance Disclosure Regulation (SFDR).

Dear Sir or Madam, As Frances public accounting standard-setter, the Autorité des Normes Comptables (ANC) welcomes the opportunity to respond to the European Commissions call for evidence on the revision of the Sustainable Finance Disclosure Regulation (SFDR).

European (re)insurers support an SFDR review focused on improving clarity, usability, and coherencewhile preserving its core role as a transparency framework, not a formal labelling regime. Maintaining this structure ensures flexibility for diverse sustainability strategies and insurance product types.

TCS values the opportunity to provide feedback on the EC's review of the SFDR and its ongoing efforts to simplify its implementation. The SFDR is a crucial tool in tackling climate change and plays a key role in transitioning to a sustainable economy. We have set out the recommendations below to improve the framework's usability and transparency for end-investors, with a particular focus on data management.

AMICE welcomes the opportunity to provide its feedback on the European Commissions call for evidence on the revision of the Sustainable Finance Disclosure Regulation (SFDR). AMICE supports the Commissions initiative to improve the functioning of the SFDR in line with the objectives of the Commissions proposals to simplify sustainability reporting for companies.

The UK Sustainable Investment and Finance Association (UKSIF) would strongly welcome the SFDR review considering how this framework can be enhanced further to the benefit of financial market participants, investors, and clients across Europe.

FEBEA welcomes the opportunity to contribute to the European Commissions review of the Sustainable Finance Disclosure Regulation (SFDR).This submission outlines five key recommendations to improve the effectiveness of the SFDR: 1. Clear and enforceable minimum standards for sustainability-related product categories. 2. Mandatory fossil fuel exclusions for all funds making esg claims. 3.

The Polish Chamber of Insurance (PIU) would like to thank you for the opportunity to express its position as part of the ongoing call for advice on the revision of the SFDR. PIUs position paper submitted in the context of this consultation has been included in the attachment.

The Luxembourg Banking Association (ABBL) welcomes the opportunity to contribute to this Call for Evidence regarding the revision of the Sustainable Finance Disclosure Regulation (SFDR). We are pleased to present our detailed comments below. We thank you for inviting our input and remain at your disposal should you require any further information or wish to engage in further discussion.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the European Commissions Call for evidence on revision of the rules on sustainable finance disclosures, published 2 May 2025. The Call for evidence acknowledges the broad market support for improving the Sustainable Finance Disclosure Regulation (SFDR).

The EU platform's suggestions are commendable. Below additional ideas from Tracefi to simplify the SFDR reporting process. Streamlining naming conventions and structure 1. Clarify the reporting by integrating the six EU environmental goals into the structure of the report.

Central and Eastern Europe is starting the transition to a green economy from a significantly different level than other regions in Europe. As a result, it is important for our Czech insurance market to ensure a smooth transition process, specifically to apply a phased approach, ensure recognition of transition efforts and provide objective reporting standards.

Union Investment welcomes the opportunity to contribute to this Call for Evidence. As the asset manager within the German cooperative financial network, we managed 146.6 bn in accordance with Art. 8/9 SFDR at the end of 2024. In this regard, the SFDR review is highly relevant to us and we support the idea to establish product categories.

Opinion of the Federal Association of Central Investment Partners (BMI) in the framework of the open consultation of the European Commission on the revision of EU rules on sustainability-related disclosures in the financial services sector (attached)

Filed in German · English published by the European Commission

We welcome the opportunity to provide input. This is a chance to improve clarity around sustainable investments and support investor decisions. We suggest the following principles to guide this process: Product distributors, such as wealth managers, advisers etc., have stressed the importance of a stable regime to support long-term product development, build trust, and avoid investor confusion - all critical to…

The Association of Real Estate Funds welcomes the European Commissions review of the Sustainable Finance Disclosure Regulation. We appreciate the opportunity to contribute insights from the perspective of the real estate investment sector in our attached response. If you would like to discuss any aspect of the response, please contact Jacqui Bungay, Head of Policy at AREF.

CDP is the Italian National Promotional Institution, with total assets above 470bn. With 4.7bn assets under management, CDP Venture Capital (CDP VC) is the VC arm of the CDP Group, supporting the Italian innovation ecosystem across all venture stages. While we recognise the value of the SFDR, enabling investors in innovation to contribute to EU sustainability goals requires the following actions: 1.

The Sustainable Finance Disclosures Regulation (SFDR) has been in application since March 2021. It is part of a broader package of sustainability disclosure rules adopted to deliver on the objectives of the Green Deal.

The German insurers (GDV) support the simplification of the SFDR to restore its value as a customer information tool. We emphasise that any such system must align with an updated IDD framework. We explicitly support the proposals by the Platform on Sustainable Finance (PSF) and the German Sustainable Finance Advisory Council.

As association of German listed and capital markets-oriented companies as well as German CFO network, Deutsches Aktieninstitut welcomes the review of the Sustainable Finance Disclosure Regulation (SFDR). Against the backdrop of the current debate on the competitiveness of European enterprises, the review bears a unique chance to fully align the SFDR with corporate reporting requirements under the Corporate…

At Holtara (an Apex Group company), we are dedicated to supporting clients in meeting their obligations under the Sustainable Finance Disclosure Regulation (SFDR). We welcome this call for evidence and appreciate the opportunity to contribute our insights based on extensive hands-on experience with the regulations implementation.

Insight Investment is one of the largest investment managers in the UK, managing £626bn in assets , primarily for UK pension funds, as well as insurers, sovereign wealth funds and financial institutions. Insight welcomes the European Commission (EC)s call for evidence for an impact assessment on the Sustainable Finance Disclosure Regulation (SFDR) review.

INVERCO is the Spanish Association of Collective Investment Institutions and Pension Funds. It represents more than 860,674 million euros in assets under management, channelling the savings of 24 million unit-holder accounts in Investment Funds and Investment Companies and more than 10 million in Pension Funds.

The Swiss Finance Council (SFC) and the Bank Policy Institute (BPI) welcome the opportunity to contribute to the European Commission's Call for Evidence to inform the Impact Assessment for the intended SFDR Review. As such, please find our joint association response attached.

INVERCO is the Spanish Association of Collective Investment Institutions and Pension Funds. It represents more than 860,674 million euros in assets under management, channelling the savings of 24 million unit-holder accounts in Investment Funds and Investment Companies and more than 10 million in Pension Funds.

The CNMV supports the European Commissions objective to improve the functioning of the Sustainable Finance Disclosure Regulation (SFDR) by addressing unnecessary burdens, enhancing effectiveness, and clarifying requirements. Particular attention should be given to improving accessibility and comprehensibility for retail investors.

I. INTRODUCTION INVERCO is the Spanish Association of Collective Investment Institutions and Pension Funds. It represents more than 860,674 million euros in assets under management, channelling the savings of 24 million unit-holder accounts in Investment Funds and Investment Companies and more than 10 million in Pension Funds.

Urgewald welcomes the opportunity to contribute to the Commissions call for evidence. The Sustainable Finance Disclosure Regulation (SFDR) has been fundamental to increasing sustainability awareness and information from and for investors. We welcome a targeted revision of SFDR to correct shortcomings of the current legislation.

(I) Regarding the importance and regulatory treatment of alternative Investments/private markets, and especially infrastructure, under the SFDR, BAI advocates that (1) The importance of private maket asset classes, such as infrastructure, real estate, private equity and private debt for the transformation and transition of the European economy, their importance in the portfolio of institutional investors and their…

As a small asset management firm with three UCITS V funds in the industrial- and precious-metals sectorsincluding one fund that promotes social and environmental characteristics pursuant to Article 8 of the Sustainable Finance Disclosure Regulationwe face the following challenges: 1.

We would like to underline the importance of ensuring consistency between the SFDR and other pillars of the EU sustainable finance framework, particularly the EU Taxonomy Regulation. The current ambiguity in the interpretation of the Do No Significant Harm (DNSH) criteria, specifically as it applies to Waste-to-Energy (WtE), is creating uncertainty for financial market participants, discouraging private investment…

In December 2023, the Central Bank of Ireland responded to the consultation on the SFDR. Our views remain. Furthermore, in light of new developments: 1. Omnibus Simplification Proposal: the potential reduction of corporate sustainability information owing to the decrease of companies within the scope of the CSRD, and proposed reduction of requirements regarding transition plans in the CSDDD, as part of Commission…

The SFDR is a critical part of the EU sustainable finance framework and has been very successful to raise awareness of investors on sustainability issues. Our WWF targeted recommendations focus on the very specific areas that need improvement.

Aéma Groupe supports the creation of sustainable product categories as part of the revision of the SFDR (option 2). The establishment of sustainable product categories at EU level is key to tackling greenwashing and ensuring regulatory coherence on sustainable finance.

The European Public Real Estate Association (EPRA) welcomes the opportunity to share our insights and vision on the future of the Sustainable Financial Disclosure Regulation (SFDR). EPRAs feedback is focused on the listed real estate sector due to the Associations sector specific knowledge and experience.

ZIA's more than 400 members include around 40 AIFM that manage real estate funds with assets in the triple-digit billion range. ZIA expressly supports the European sustainable finance agenda, and particularly the SFDR.

The AFM would like to take this opportunity to highlight main areas for simplification and burden reduction, for all stakeholders in the market, incl. market participants, distributors, and investors. Attached you may also find a letter co-signed by the AFM, BaFin and FMA. The revised framework should be easy to understand and easy to implement for all stakeholders.

(1) the commitment of Ofi Invest AM in relation to the objectives of SFDR OFI Invest AM fully supports SFDR’s initial lobjective to help channel private finance to facilitate the transition of economic actors towards greater sustainability. By improving the transparency and readability of ESG information on issuers and investment media, SFDR enables ESG earmarking of investments.

Filed in French · English published by the European Commission

Please see attached file containing the CNMVs Advisory Committee contribution. The CNMV's Advisory Committee has been set by the Spanish Securities Market Law as the consultative body of the CNMV. It is composed by market participants and its opinions are independent from those of the CNMV.

Attached please the Irish Funds Industry Association (Irish Funds) full and detailed response to the Commission's Call for Evidence on the revision of EU rules on sustainable finance disclosure. Irish Funds is the representative body for the international investment funds industry in Ireland.

SFDR is a fundamental tool to help investors reallocate capital towards a more sustainable economy; however the current framework has shortcomings - notably the complexity of disclosures, the classification system and cross-regulation alignment, including with revised versions of the CSRD, ESRS and EU Taxonomy in the Omnibus package.

We reiterate the need for a revision of the SFDR Regulation in order to simplify the information requirements and overcome the current difficulties of interpretation and application. This is all the more urgent today to ensure consistency with initiatives aimed at simplifying corporate sustainability reporting and with the strategic objectives of the Savings and Investments Union.

Filed in Italian · English published by the European Commission

The Steyler Ethik Bank, as an ethical and sustainable bank and investor, would like to focus on one topic and express our concern about classifying weapons and military equipment as sustainable according to SFDR. We don't think there's any point in "helping to attract private funding" when it comes to the actual stock price development of weapon producers.

Please find attached the full ASN Impact Investors feedback to the EC Call for Evidence in SFDR. Executive summary ASN Impact Investors has over 30 years of experience as a sustainability-focused asset manager in the Netherlands.

Key messages: - SFDR regulation should be better aligned with PAB and CSRD. Definition of sustainable investments should be enhanced. - Current classification of art. 6, 8 and 9 should be changed into a five-point scale of sustainability. - Reporting burden can be reduced through strengthening product disclosure, reducing entity level disclosure and aligning website and precontractual information. 1.

IIGCC supports the broad aims of the SFDR review, which should help to address usability and implementation challenges while also preserving the Regulations objectives to promote transparency and channel finance towards sustainability-focused investment strategies.

The Investment Company Institute (ICI) appreciates the opportunity to share our views on the European Commissions call for evidence on the review of the Sustainable Finance Disclosure Regulation (SFDR). ICI welcomes the Commissions focus on how to improve the functioning of the SFDRboth for financial market participants and for end investors.

SFDR plays a central role in the sustainable finance framework as it is meant to build the bridge between the real economy's financing needs and investors looking for green(er) investment opportunities. Hence, it is key for SFDR to be designed in a way that provides adequate information on sustainability characteristics of financial products, enabling investors to make an informed judgement about the investments…

SFDR 2.0 CONSULTATION TEXT e-MFP and Cerise+SPTF, financial inclusion networks representing social- and impact-finance actors investing in emerging markets, welcome the revision of the Sustainable Finance Disclosure Regulation (SFDR).

Climate & Company welcomes the opportunity to contribute to the Commissions call for evidence. The high-level recommendations below build on our feedback to the 2023 targeted consultation and our 2024 white paper Transition products Conceptual Clarity & Implementation Guidance, which demonstrates that robust transition criteria can coexist with competitive risk-adjusted returns in public equity portfolios.

e-MFP and Cerise+SPTF, financial inclusion networks representing social- and impact-finance actors investing in emerging markets, welcome the revision of the Sustainable Finance Disclosure Regulation (SFDR). We view SFDR 2.0 as an opportunity for the EU to both strengthen internal market competitiveness and build a global safe harbour for capital that pursues environmental and social impact alongside financial…

We welcome that the EU Commission has launched a Call for Evidence to improve the usability and impact of the current framework. However, we regret that the Commission has not taken the opportunity to review the SFDR together with the Omnibus I package as the two legislative frameworks are closely linked to each other but lack consistency and should be aligned.

Assogestioni supports the ECs aim to enhance clarity, coherence, and usability of SFDR. The review should align with the broader EU sustainable finance framework and prescribe disclosure which is decision-useful for retail investors and less burdensome for FMPs.

Summary points from our detailed paper include: Effective interoperability across markets benefits clients, firms and Europes competitiveness and should be a guiding principle. Omnibus: any changes to the corporate reporting requirements, including Taxonomy reporting, must be fully reflected in the SFDR review. FMPs should not be required to disclose information that corporates themselves are not obliged to report.

In June 2024, the European Supervisory Authorities (ESAs) published the "Joint ESAs Opinion on the assessment of the Sustainable Finance Disclosure Regulation (SFDR)" (https://www.esma.europa.eu/sites/default/files/2024-06/JC_2024_06_Joint_ESAs_Opinion_on_SFDR.pdf).

ANIA, the Italian Insurance Association, deems important to revise the SFDR framework in order to render it more effective to promote sustainable finance, while simplifying it in the interest both of financial market participants and of their clients.

Designed as a key component of the EUs Sustainable Finance framework, the Sustainable Finance Disclosure Regulation (SFDR) was intended to be complementary to the Taxonomy Regulation and the Corporate Sustainability Reporting Directive (CSRD).

I suggest two reforms to SFDR to increase the impact and reduce the burden on asset managers. 1) Automatic and consistent fund-level metrics Currently, each asset manager is required to collect and report the metrics for each fund (e,g, PAI, taxonomy 2.18 etc). This places a significant burden on each asset manager and leads to inconsistent reporting.

e-MFP and Cerise+SPTF, financial inclusion networks representing social- and impact-finance actors investing in emerging markets, welcome the revision of the Sustainable Finance Disclosure Regulation (SFDR). We view SFDR 2.0 as an opportunity for the EU to both strengthen internal market competitiveness and build a global safe harbour for capital that pursues environmental and social impact alongside financial…

In the current context, everything that is associated with simplification is linked to deregulating and dismantling the European Green Deal, which seems to be the cause of all the economic problems in the EU. Before simplification, we need to reflect on the problem, as the aim is to simplify rules that have little way and implementation enough to reflect inefficiencies.

Filed in Spanish · English published by the European Commission

Confindustria Assoimmobiliare welcomed the opportunity to contribute to the public consultation on the revision of the European Sustainable Finance Disclosure Regulation (SFDR). Following an internal assessment, a series of detailed observations and targeted proposals have been developed.

We confirm the paramount importance to revise the Sustainable Finance Disclosure Regulation (SFDR) to effectively simplify the current disclosure requirements and to resolve the numerous issues in the interpretation and implementation of current requirements, as already represented in our response to the preliminary consultation in 2023.

Neuberger Berman supports the SFDR's aim to improve transparency on how asset managers integrate sustainability risks. While we support its objectives, the framework faces challenges that must be addressed to deliver decision-useful information and support sustainable finance in the EU: 1.

CSRD for large companies is complementary to the SFDR in that it provides (part of) the information for investment funds to report under SFDR. In this way, the SFDR can also help reduce the administrative burden for companies reporting under CSRD through standardization of information requests made to these companies by fund managers.

Impact Europe, together with the United4Impact coalition, is pleased to submit the attached paper as part of our contribution to the European Commissions consultation on the revision of the Sustainable Finance Disclosure Regulation (SFDR). The paper sets out a concrete and actionable proposal for the creation of an impact investing product category within the revised SFDR framework.

Crédit Agricole very much welcomes the Commissions intension to review SFDR. While we share the objectives of the regulation, we also think that major changes should be introduced to make it relevant for final investors and workable for stakeholders in charge of implementing it. 1.

AFEP, the French Association of Large Companies, welcomes this call for evidence on the Sustainable Finance Disclosure Regulation (SFDR). AFEP Members support the objectives of the SFDR to attract private funding to facilitate the transition towards greater sustainability and help European companies to seize competitive opportunities.

EUSIPA strongly supports the regulatory landscape in the area of sustainable finance undergoing a recalibration and simplification effort. This effort ultimately should resolve the current absence of a substantive alignment between the SFDR rules and others, equally important regulatory frameworks such as MIFID and IDD, as well as important further cornerstones of product information disclosure such as the EU PRIIPs…

The feedback from the French Autorité des marchés financiers focuses on the three following messages. See details in the document attached. 1) AMF strongly supports the direction of travel envisaged by the Commission, especially the introduction of product categories and the streamlining of disclosure requirements.

ShareAction welcomes the opportunity to contribute to the review of the Sustainable Finance Disclosure Regulation (SFDR). This submission draws on the findings of our recent report, Bridging the Data Divide: An analysis of market practice to strengthen engagement disclosures under the Sustainable Finance Disclosure Regulation (SFDR), which assesses the due diligence and engagement disclosures of 30 of the largest…

AMAFI welcomes the opportunity to share its views on the revision of the Sustainable Finance Disclosure Regulation (SFDR) as part of the European Commission call for evidence. The SFDR review is expected to deliver a thorough reassessment of the framework and provides a key opportunity to address several longstanding challenges, notably: - The current exclusion of structured products from its scope, even though some…

The German Structured Securities Association (Bundesverband für strukturierte Wertpapiere, BSW) welcomes the opportunity to respond to the European Commissions call for evidence for an impact assessment on the revision of the Sustainable Finance Disclosure Regulation (SFDR). Please find attached our response to the call for evidence.

#UnitedforImpact, a coalition of 64 impact investors from 18 EU countries, together with Impact Europe, welcome the European Commission's upcoming review of the Sustainable Finance Disclosure Regulation (SFDR). Our two organisations are pleased to share with the Commission a Technical paper on the inclusion of an Impact product category under the SFDR.

CONTEXT The implementation of the Sustainable Finance Disclosure Regulation (SFDR) has been a learning process due to its lack of clarity. Key challenges faced by funds in achieving ESG compliance include: - Unclear definitions/concepts or confusion on ESG terminology (Sustainable finance, DNSH/PAI), - Lack of harmonized and verified ESG data for Startups, SMEs and Real Estate, - An evolving reporting template and…

PRI welcomes the European Commissions upcoming review of the Sustainable Finance Disclosure Regulation (SFDR). As a central component of the EU sustainable finance framework, it is essential that the regulation functions effectively and delivers on its objectives. This consultation represents an important opportunity to identify challenges and enhance regulatory clarity.

The Investment Property Forum (IPF) welcomes the European Commissions review of the Sustainable Finance Disclosure Regulation (SFDR) and appreciates the opportunity to contribute evidence-based insights from the perspective of the real estate investment sector.

We appreciate the opportunity to comment on the European Commissions (EC) Call for evidence on the revision of the Sustainable Finance Disclosure Regulation (SFDR). We have consulted with our member firms to ensure the letter attached represents the views of the KPMG network.

As a major financing operator of sustainability in France as well as a long-term institutional investor with a long-standing commitment to responsible investment, the Caisse des Dépôts group highly supports the concepts and disclosures that the SFDR requires and thanks the European Commission for the opportunity to provide its opinion on how to improve the functioning of the SFDR.

We generally share the high-level conclusions of the EU COM derived from the comprehensive assessment on the SFDR conducted in 2023 and agree with the EU COMs objectives for the SFDR review. While hinting at our contribution to the SFDR public consultation in December 2023, we would like to highlight the following points at this stage: (A) A categorization system for financial products can help facilitate retail…

The SFDR currently serves as a structuring framework for sustainable finance in Europe. Its main strengths include: 1) Increased transparency obligations: The regulation requires financial actors to disclose how they take sustainability criteria into account in their investment decisions.

The Sustainable Finance Observatorys response to the Call for Evidence on the revision of the Sustainable Finance Disclosure Regulation is set out in the attached document which sets out 5 critical issues which must be addressed: - Critical Issue 1: Any new approach to sustainable financial product categorisation must be based on retail investors sustainability-related objectives and integrate the concept of…

e-MFP and Cerise+SPTF, financial inclusion networks representing social- and impact-finance actors investing in emerging markets, welcome the revision of the Sustainable Finance Disclosure Regulation (SFDR). We view SFDR 2.0 as an opportunity for the EU to both strengthen internal market competitiveness and build a global safe harbour for capital that pursues environmental and social impact alongside financial…

We welcome the European Commission's initiative to review the area and design an optimal system that meets the needs and interests of the market and customers. As a financial market participants, we strongly support the European Commission's efforts to make the activities of the financial sector more transparent, to prioritise sustainability goals in the financial sector and to contribute to their achievement.

The Sustainable Banking Coalition welcomes the upcoming review of the SFDR by the European Commission. The Coalition recognizes the SFDR as a key piece of the EU sustainable transparency framework. Its upcoming review presents a timely opportunity to address ambiguities identified through practical experience with the regulation, streamline navigation challenges, and strengthen its applicability.

Executive summary The Sustainable Finance Disclosure Regulation (SFDR) is an important instrument in combating climate change. Capital flows are to be steered towards sustainable investments and greenwashing prevented through transparency. The current review of the SFDR should be used to improve transparency and comprehensibility for investors with targeted amendments.

Executive summary The Sustainable Finance Disclosure Regulation (SFDR) is an important instrument in combating climate change. Capital flows are to be steered towards sustainable investments and greenwashing prevented through transparency. The current review of the SFDR should be used to improve transparency and comprehensibility for investors with targeted amendments.

France Assureurs fully supports the SFDR and considers it to be a fundamental tool in contributing to the transition towards a sustainable economy. Although it was designed as a transparency regime, the market uses it in practice as a labelling system.

Deutsche Börse Group (DBG) welcomes the ECs review of the SFDR alongside its continued simplification and burden reduction efforts within the sustainable finance framework. Firstly, we fully agree with the objectives of the SFDR in fostering an investment in sustainable finance and secondly, we share the critique raised by various stakeholders on the shortcomings of the current framework.

The SFDRs objectives are still relevant. However, there are many shortcomings with the interpretation and implementation of existing requirements, and we welcome the upcoming revision of the SFDR to strengthen the effectiveness of the regulation. We have set out recommendations to improve the framework's usability and transparency for end-investors, with a particular focus on retail investors. Our key messages: 1.

The AFG totally supports the efforts of European co-legislators towards financing a more sustainable economy. The SFDR framework has been in application for a few years now and our members already see a positive impact. Its implementation has however been raising numerous challenges and concerns among authorities, financial market participants and investors.

ADEME, the French Agency for Ecological Transition, thanks and supports the EU Commission in the SFDR review. ADEME has already published a position paper regarding the need of SFDR review, annexed to the current answer. The recent Omnibus proposals regarding CSRD and Taxonomy frameworks have a direct impact on SFDR, but the core messages remain.

We agree with the limitations of the SFDR the Commission has pointed out in the call for evidence. The objective of the sustainable finance legislation, however, remains fully valid. We therefore support the Commissions efforts to simplify key concepts, streamline and reduce disclosure requirements, and the introduction of clear and simple product categories.

As a professional services firm that assists clients with implementing the SFDR, we welcome the opportunity to respond to the Call for Evidence launched by the European Commission to review EU rules on sustainable finance disclosure.

The Sustainable Finance Disclosure Regulation (SFDR) review is a significant opportunity to scale-up finance for sustainable growth and the decarbonisation of the European economy, in line with the EUs strategic objectives. The implementation of SFDR significantly improved disclosures on, and consideration of sustainability risks and adverse sustainability impacts in investment decisions.

PLANETE CSCA supports the Commissions general intention to simplify existing regulations, especially in the sustainability field, where the regulatory framework is extremely complex (regarding the number of texts adopted and complexity of these requirements). PLANETE CSCA is in favor of all sustainable initiative but considered that if the legislation is too complex to apply, it loses all benefits.

Temperans welcomes the initiative to review the SFDR and shares the EC view that the framework needs simplification, clarification, and better alignment with other sustainability-related regulations. The current framework clearly defines sustainable investment at the asset level.

1. Product classification: We support the establishment of a voluntary system of product categorisation based on the sustainability propositions of financial products. We recommend distinguishing three product categories in correspondence to the PSF proposal: - Focus on positive contribution to an environmental/social objective (sustainable): This category would encompass products that aim at making a measurable…

As an working group of chruch investors we would like to make the following coments: SFDR 2/17 states: Sustainable investment means an investment in an economic activity that contributes to an environmental objective, () or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social…

Joint Letter to the Commission on the Revision of the SFDR Regarding the recent developments on the SFDR review, we would like to highlight some aspects that are of main importance for us as national supervisors.

To make SFDR understandable and useful for all stakeholders, we believe it would be necessary for a new regulation to distinguish between several categories of responsible investment. Solutions_ A first approach to responsible investment, often referred to as impact or thematic investing, involves investing in companies whose products and services address environmental or social challenges.

Finance Watch welcomes the opportunity to respond to the call for evidence on the revision of the Sustainable Finance Disclosure Regulation (SFDR). The SFDR has played an important role in raising awareness and paving the way for the sustainable finance framework. However, the design of the SFDR as a pure disclosure framework has quickly proven to have limits.

AMUNDI totally supports the efforts of European co-legislators towards financing a more sustainable economy. The Sustainable Finance Disclosure Regulation (SFDR) framework has been in application for a few years now and we already see a positive impact. Its implementation has however been raising numerous challenges and concerns among authorities, financial market participants and investors.

The SFRD's vagueness and complexity has meant that the regulation has not delivered on its promise to clarify what are sustainable investments and funds. Wikirate International welcomes simplifications that will help strengthen the usefulness of the regulation and reliability of disclosures, whilst calling for caution to avoid it becoming a superficial tick-box exercise or worse, a tool to green-wash investments and…

Pacific Asset Management welcomes the objective of the European Commission to streamline and simplify the SFDR. Through this text we aim to present our collective opinion concerning key concepts, disclosure requirements and product categories. The current definition of sustainable investments (art. 2(17) of Reg 2019/2088) is too vague and ambiguous, leading to differing interpretations by FMPs.

As an academic researcher specializing in sustainable finance, I have reviewed hundreds of SFDR-related disclosures on private equity fund websites. Based on this extensive reading on the disclosure practice of SFDR, in combination the discussion with our professors in Vlerick Sustainability Centre, we would like to highlight two issues where SFDR could be strengthened: (1) the conceptual clarity of sustainable…

SIFA welcomes the initiative to review the SFDR and shares the European Commissions view that the framework needs simplification, clarification, and better alignment with other sustainability-related regulations. We emphasise the importance of ensuring a realistic timeline and adequate transition period for the effective implementation of any changes to the SFDR.

France Invest brings together venture capital, private equity, infrastructure and private debt teams based in France, as well as the associated professions which support them. Its membership currently counts roughly 460 management firms and 200 associate members. France Invest thanks the Commission for the opportunity to share comments on the SFDR revision.

Capital Group welcomes the opportunity to respond to the European Commissions call for evidence, published on 2 May, to inform the impact assessment for the revision of the Sustainable Finance Disclosure Regulation (hereafter SFDR). CG submitted its response to the targeted consultation on SFDR implementation, in December 2023.

The Central Association of German Crafts (ZDH), as the umbrella association for crafts, represents the interests of around 1 million craft businesses with more than 5.6 million employees and around 350.000 apprentices. As part of the first Omnibus package, the European Commission has proposed simplifications, including on CSRD and CSDDD.

Filed in German · English published by the European Commission

The upcoming review of the Sustainable Finance Disclosures Regulation (SFDR) presents a golden opportunity to further facilitate consumer involvement in Europes capital markets by ensuring sustainable investment products are held to a high standard, allowing consumers to invest in products that match their preferences.

The broader aims of the Sustainable Finance Disclosure Regulation (SFDR) are to support the transition to a more sustainable economy by attracting private capital and helping European companies to seize competitive opportunities in this space.

The Financial Supervisory Authority of Norway (Finanstilsynet) supports the work being done under the SFDR, which has contributed to greater transparency and increased focus on sustainability in financial products.

Dear DG FISMA Unit C4 Asset management team, The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) welcomes the opportunity to respond to the Call for Evidence on the revision of SFDR. We hope our attached comments will make a constructive contribution to this important topic. If you have any questions or would like to discuss our response, please contact me at [email removed].

The Commissions assessment rightly points out limitations in the current SFDR framework that hinder private investment in the sustainable transition and risk excluding certain sectors. To avoid a fragmented single market for sustainable finance, Union-level action is needed to simplify the existing framework.

LBP AM welcomes the strong emphasis that the SFDR put on ESG issues, leading to widespread consideration of such issues at senior levels into Financial Market Participants (FMPs) organizations. However, the absence of minimum standards combined with the abusive use of the SFDR regime as a labelling regime and the technical discrepancy with MIFID II/IDD provisions have made the framework difficult to use and did not…

Please find herebelow the link to the white paper we prepared at DigitalTrade4EU: https://ramenax-my.sharepoint.com/:w:/g/personal/riho_vedler_ramena_ee/EcD29Bl7An1BkyZXIN4HlaQBxQj6Sx55EzOV1y4zGyLsbQ?e=ctfiep Very importantly, we believe Sustainable Finance will require: 1. further digitalisation (MLETR), 2.

We support the principles and objectives of the Sustainable Finance Disclosure Regulation (SFDR), essential for a single market for sustainable investment products. Without the SFDR, country-specific requirements would proliferate, complicating cross-border sustainable product provision. Changes to the SFDR should balance regulatory stability with necessary adjustments to improve investor information.

Lannebo supports the objectives of the SFDR review and welcomes the ambition to simplify the regulatory framework. For asset managers with a large number of fundsoften more than 30it is crucial that the simplification results in a tangible reduction in administrative burden. We believe that pre-contractual disclosures should focus on clearly and comparably describing established sustainable investment strategies.

Janus Henderson Investors is a leading global active asset manager with more than 25 offices worldwide and 345.5bn of AuM as of 31st March 2025. We welcome the opportunity to respond to this Call for Evidence and to consider any improvements that can be made to the SFDR in light of the Commissions stated objective to improve the functioning of the framework, address undue burdens and simplify requirements.

The Federal Association for the Promotion of Insurance Brokers (BFV: https://www.bfv-versicherungsmakler.de/) in its opinion to EIOPA (https://www.bfv-versicherungsmakler.de/wp-content/uploads/2022/05/2022_05_13_BFV-Stellungnahme-EIOPA-Konsultation-Nachhaltigkeitspraeferenzen.pdf) already in May 2022 criticised the consultation procedure in relation to the obligation to obtain sustainability preference (insurance…

Filed in German · English published by the European Commission

Context 1. The White Paper for European Defence Readiness 2030 issued by the European Commission last March underscores the need to create a stronger and more resilient defence industrial base also by removing obstacles related to its access to finance, including ESG investment.

The revision of the SFDR Regulation represents a crucial moment for the evolution of sustainable finance in Europe. Anasf the National Association of Financial Advisors in Italy has expressed proactive positions in the context of the European debate, highlighting both operational criticalities and areas for regulatory improvement.

The categorization of funds under the SFRD should be streamlined including clear definitions and linkages with products available in the markets as well as clearly aligned with ESG strategies of Financial Market Participants To this end, it is key to ensure consistency with performance indicators, ideally to be assessed by means of both voluntary and mandatory standards.

Assuralia welcomes the European Commissions initiative and supports a review focused on improving clarity, usability, and coherence. Given the significant efforts already made by (re)insurers to implement the current framework, particularly regarding the now established Articles 6, 8, and 9 product classifications, this approach would be a practical and effective way to enhance the regulations functioning.

For 414's extended feedback, please refer to the submission attached. At the core of our recommendations is the need for a unified, consolidated legal text or digital tool that brings together the main regulation, all existing soft law clarifications, Q&As, and outstanding interpretive issues into a single, accessible reference.

The Sustainable Finance Disclosure Regulation (SFDR) adopted in 2019 triggered a vast movement of self-labelling by asset managers. SFDRs articles 8 and 9 quickly became a source of confusion, notably due to the lack of clear criteria for each category. Category assignments were regularly modified without justification by asset managers depending on internal assessments of compliance risk.

I am publishing this feedback on behalf of Tracenable, an ESG data provider with over five years of experience delivering structured, high-integrity datasets to financial institutions, asset managers, and platform providers across the EU.

Good morning, Our view is that the burden of regulation comes through making regulatory changes. I think the current system works reasonable well and the recent UK FCA SDR regulation which tried to implement a different/superior approach has not worked out well. Our view is to maintain the current approach as much as possible i.e. having the Article 6, 8 and 9 classifications.

ASPIM strongly supports the sustainable finance agenda and shares the EUs political goal to channel investment towards the climate transition to fulfill its commitments under the Paris Agreement. We are resolutely committed to promote the integration of ESG standards into the management of non-listed real estate investment funds and to ensure they are involved in completing ambitious goals on social responsibility.