Letter to the ESAs – Requesting clarifications around the Principle Adverse Impact Indicators of the SFDR

14 May 2021

On behalf of Eurosif, the European Sustainable Investment Forum, we request from the European Supervisory Authorities some technical modifications regarding certain principal adverse impact indicators (PAII) described in the draft Regulatory Technical Standards (RTS) of the EU Sustainable Finance Disclosure Regulation (SFDR) (EU) 2019/2088.

We believe these technical modifications would contribute to the coherent and uniform interpretation of these indicators by both financial markets participants (FMPs) and data providers on which FMP will need to rely to ensure. This will in turn improve the comparability of disclosures between reporting entities. 

We are not advocating for a revision of the RTS or the modification, addition, or deletion of any indicators but merely inserting helpful clarifications to the first set of SFDR RTS. We believe these technical modifications could be included in the joint report of the ESAs on the RTS on Taxonomy Alignment which will amend the first set of SFDR RTS and will be submitted to the European Commission in the month of June we understand.

 Brussels, May 14th 2021 - Read our full letter here