DUFAS

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the European Commissions Call for evidence for review of the Climate and Environmental delegated acts. In our response, we outline various elements of the framework that, from a global investor perspective, would benefit from further improvement.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the European Commissions proposed revision of the European Sustainability Reporting Standards (ESRS), which strike an appropriate balance between simplifying reporting requirements and preserving the core principle of double materiality.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to comment on the draft proposal to amend the Climate Delegated Act and annexes. Our response focuses on several areas where we see clear improvements, as well as a number of concerns regarding the level of ambition and the robustness of the do no significant harm (DNSH) criteria.

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.

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).

DUFAS strongly supports the development of a solid corporate sustainability reporting framework and sustainability standards. We believe that CSRD will improve the quality of sustainability information and increase the comparability of ESG data between investee companies.

The Dutch Fund and Asset Management Association (DUFAS) supports the European Commissions Digital Fitness Check, which evaluates the cumulative impact of EU digital regulation. Strengthening digital resilience, protecting investors, and safeguarding market integrity are important objectives for the asset management sector.

Executive Summary DUFAS welcomes the opportunity to respond to their extensive reform proposal of the EU legislative framework for retail investments, the Retail Investment Strategy (RIS) as published on 24 May 2023. We strongly support the objective of the RIS to boosting better access of retail participation in the financial markets. We do appreciate the European Commission's comprehensive work in this field.

DUFAS welcomes the European Commissions ambition to take further steps towards creating a well-functioning, integrated, and internationally competitive European capital market through the Market Integration Package (MIP).

DUFAS welcomes the European Commissions ambition to take further steps towards creating a well-functioning, integrated, and internationally competitive European capital market through the Market Integration Package (MIP).

Executive summary DUFAS and its members welcomes the proposal for regulation on the transparency and integrity of ESG rating activities. ESG ratings and ESG data are important for asset managers. DUFAS and its members emphasize therefore the need for a well-functioning ESG ratings market that provides relevant, reliable, and comparable ESG ratings.

The Dutch Fund and Asset Management Association (DUFAS) supports the core objectives of the Shareholder Rights Directive (SRD): facilitating the effective exercise of shareholder rights, strengthening shareholder engagement, and protecting minority shareholders. Active and sustainable shareholder involvement remains a key pillar of corporate governance and long-term value creation.

DUFAS supports the development of a European Single Access Point as it will improve data availability for asset managers and other stakeholders. We see most merit in additional data availability related to sustainability regulations/directives like NFRD, CSRD, the Taxonomy Regulation and the SFDR.

DUFAS (Dutch Fund and Asset Management Association) welcomes the European Commission’s (EC) review of the Alternative Investment Fund Management Directive (AIFMD) and its aim to set out targeted improvements to key provisions in the current framework.

The Pan-European Personal Pension Product (PEPP) was launched in 2019 with high hopes of providing a simple and portable retirement savings plan across the EU. However, since PEPPs became available in 2022, uptake has been disappointingly low, by the end of 2025, only two providers had launched a PEPP across the entire EU.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the European Commissions proposal of 20 November 2024 to boost supplementary pensions and help ensure adequate retirement incomes across the EU. This comprehensive package includes non-binding recommendations for Member States on pension tracking systems, pension dashboards, and auto-enrolment, as well as two legislative proposals to amend the IORP II…