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.
KPM
KPMG
Company · Germany
2
positions filed
in the 326 files tracked
2
legislative files
of 326 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
KPMG filed 2 positions between 22 Apr 2025 and 28 May 2025, across 2 of the 326 legislative files tracked here, attaching a full position paper 2 times.
What they argued
While reviewing both uploaded documents regarding the amendments, I noticed what appears to be a discrepancy between the two texts. In the draft of the delegated regulation (page 2), it states:"The relevant products listed under Wood in Annex I to Regulation (EU) 2023/1115 do fall within the scope of that Regulation if they are made solely of bamboo, rattan, and other materials of woody nature." However, in the…
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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.
- Cefic · 2 files in common
- WWF European Policy Office · 2 files in common
- ClientEarth · 2 files in common
Is this your organization?
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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.