IIGCC welcomes the opportunity to respond to the European Commission's consultation on the revision of the European Sustainability Reporting Standards (ESRS). We commend EFRAG's efforts to simplify the requirements while maintaining their integrity and the Commissions decision to preserve much of EFRAGs work.
Institutional Investors Group on Climate Change
NGO · United Kingdom · EU Transparency Register 962717910722-61
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #216 by legislative files engaged, a count of participation, not a measure of influence.
Declares membership of
- Member of the Investor Agenda Policy Working Group
- Marrakesh Partnership – Co-lead of the Finance Working Group (global focus)
- Member of Net Zero Taskforce, led by PRI
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Head office
- London, United kingdom
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Institutional Investors Group on Climate Change filed 7 positions between 21 Aug 2018 and 3 Jun 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 4 times.
What they argued
On behalf of the Institutional Investors Group on Climate Change (IIGCC) - see www.iigcc.org IIGCC's investor members strongly support carbon pricing as a means of sending clear, long-term investment signals to support the transition to a net zero emissions economy. IIGCC has consistently supported greater climate ambition in the EU ETS through its different Phases and reforms.
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.
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.
See attached document for full policy position. In summary, in its core recommendations IIGCC urges the EU to: 1. Set out a clear, long-term policy framework for the real economy – encompassing energy, transport and industry – backed up by concrete targets and objectives, as a priority issue, to move capital to support a transition to a sustainable low carbon economy. 2.
This feedback was developed in collaboration with a number of IIGCC members but does not necessarily represent the views of the entire membership, either individually or collectively. Priorities: Permitting. Accelerated permitting both for new renewable energy construction and for grid infrastructure.
Disclosure remains the foundation of the EUs Sustainable Finance Action Plan, and the ESRS are an essential component of this. They establish the parameters for the detailed, credible and comparable reporting needed by investors to assess their exposures to climate-related risks and opportunities, inform stewardship activities and investment decisions, and reorient capital in line with a net zero world.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.