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Bloomberg L.P.

Bloomberg L.P. is a global provider of financial information, news, and analytics.

Lobbying Activity

Meeting with Lukas Mandl (Member of the European Parliament)

30 Dec 2025 · Global Sanctions Regime

Response to Revision of EU rules on the eInvoicing

17 Dec 2025

Bloomberg notes that European companies operating across borders continue to face challenges arising from the lack of globally harmonized identification standards. These inconsistencies increase operational complexity, elevate administrative burdens, and hinder efficient international business activity. Bloomberg highlights that the Legal Entity Identifier (LEI), an ISO-based global identification system, offers an effective means of addressing these issues. By providing a single, reliable identifier supported by verified reference data, the LEI enables legal entities to be consistently recognized across jurisdictions and regulatory environments. Bloomberg believes that expanding the use of globally recognized standards such as the LEI within the EUs standardization framework would strengthen interoperability between systems, reduce duplication in identity and compliance processes, and enhance transparency for businesses and supervisory authorities. This approach would also support the EUs digital transformation priorities and help facilitate smoother cross-border operations. Given the LEIs established role in several areas of EU legislation, broadening its application would build upon a familiar and trusted identifier. Bloomberg therefore encourages the European Commission to promote the adoption of global, interoperable standards like the LEI in the revised Regulation to support business competitiveness and ensure more consistent and efficient identity management across the EU and internationally.
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Meeting with Beatrice Coda (Head of Unit Research and Innovation)

1 Oct 2025 · Presentation of 2025 BNEF Hydrogen Outlook

Meeting with Luděk Niedermayer (Member of the European Parliament)

3 Sept 2025 · Exchange of views on the ongoing economic developments

Meeting with Andreas Schwab (Member of the European Parliament)

3 Sept 2025 · Future of Europe

Meeting with Marcos Gonzalez Alvarez (Acting Head of Unit Climate Action)

28 Aug 2025 · Discussion on progress of the social climate fund and the role that Bloomberg could play in terms of data and technological support.

Meeting with Simonas Satunas (Cabinet of Commissioner Andrius Kubilius)

10 Jun 2025 · Discussion of European defence and of the “Bloomberg Intelligence's Defense Spending Outlook 2025”

Bloomberg urges EU to clarify sustainable finance disclosure rules

30 May 2025
Topic — The European Commission is reviewing sustainability disclosure rules for the financial services sector.
Message — Bloomberg requests clearer legal definitions and a uniform labeling system for financial products. They recommend harmonizing impact disclosures to improve transparency and prevent greenwashing.123
Why — Standardized data metrics allow Bloomberg to provide more accurate and comparable financial analytics.45
Impact — National authorities lose control as standardized EU labeling replaces diverse local rules and guidelines.67
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

22 May 2025 · SIU - Targeted Consultation on capital market integration and supervision

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Euronext and

16 May 2025 · Exchange with trading venues on the integration of EU capital market

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

5 May 2025 · AI

Meeting with Valdis Dombrovskis (Commissioner) and

29 Apr 2025 · EU – US trade relations EU’s development agenda, Global Gateway EU’s competitiveness agenda, including simplification

Meeting with Maria Luís Albuquerque (Commissioner) and

24 Apr 2025 · Savings and Investments Union (SIU)

Meeting with Alessandra Sgobbi (Head of Unit Climate Action)

10 Apr 2025 · Discussion on CSRD

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

3 Apr 2025 · CSRD Reporting Status quo and Omnibus impact

Bloomberg backs Taxonomy reporting simplifications while seeking more data granularity

26 Mar 2025
Topic — Consultation on simplifying EU Taxonomy disclosure requirements to reduce company reporting costs.
Message — Bloomberg supports the 10% materiality threshold but urges the Commission to maintain reporting granularity for companies. They recommend adding restated prior-year figures to templates to ensure financial market data consistency.12
Why — Improving template consistency and automating data collection would reduce Bloomberg's costs in processing company disclosures.34
Impact — Investors lose visibility because excluding smaller companies reduces disclosed Taxonomy data by 14 percent.56
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Meeting with Antonio López-Istúriz White (Member of the European Parliament)

19 Mar 2025 · State of transatlantic relations in the current geopolitical context

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

19 Mar 2025 · general presentation of ongoing activities

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

18 Mar 2025 · Interested representative and Commission representative exchanged views on the EU regulatory agenda, EU capital markets and Transatlantic relations.

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union), Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

6 Feb 2025 · Discussion on the ESMA’s final reports regarding the draft regulatory technical standards on reasonable commercial basis

Bloomberg Urges EU to Adopt Global Financial Standards

28 Jan 2025
Topic — This consultation focuses on developing an EU single market for services and goods.
Message — Bloomberg suggests the EU avoid complex bespoke rules by fully embracing international standards. They specifically urge the continued adoption of global identification standards for businesses in financial reporting.12
Why — Standardized data formats lower the cost of maintaining global financial information and databases.3
Impact — EU financial firms suffer increased costs if required to maintain separate identifiers for Europe.4
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Meeting with Francois Wakenhut (Head of Unit Environment) and Clean Air Fund

28 Jan 2025 · The implementation of Europe’s new clean air standards

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Jan 2025 · Development of AI

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and NASDAQ and

24 Jan 2025 · MiFIR Review

Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné)

24 Jan 2025 · Meeting to discuss AI development

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and FTI Consulting Belgium and

21 Jan 2025 · Benchmark Regulation

Meeting with Dirk Gotink (Member of the European Parliament)

26 Nov 2024 · MiFID and financial supervision

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

26 Nov 2024 · General presentation of objectives

Meeting with Billy Kelleher (Member of the European Parliament)

26 Nov 2024 · Capital Markets and data sharing

Meeting with Aura Salla (Member of the European Parliament)

14 Oct 2024 · Introductory meeting

Meeting with Andreas Schwab (Member of the European Parliament)

26 Sept 2024 · priorities for the new legislative mandate

Meeting with Eero Heinäluoma (Member of the European Parliament) and Platform for Electromobility

26 Sept 2024 · Current Affairs

Response to Applying a unique identifier for public transparency of OTC derivatives

8 Jul 2024

I) General Comment: Bloomberg is a strong advocate for greater transparency in financial markets as well as international regulatory convergence. In line with the vast majority of market participants, Bloomberg has been consistently clear in supporting ISO 4914 UPI as the best way forward for identifying reference data for OTC derivatives, which will help MiFIR to deliver on its transparency policy objectives for these instruments. The UPI is a global regulatory defined standard in the process of being adopted by other major jurisdictions. To better deliver on CMU objectives in regards to the OTC derivatives markets activity in the Union, the choice of identifier should align with international approaches. This would demonstrate the EUs commitment to boosting the competitiveness of the EU as a trading hub and reducing the reporting burden. This would also be in line with the clear mandate set out by the co-legislators in the MiFIR review. It is therefore regrettable that the Delegated Act excludes the possibility to utilise the UPI as a basis for this reporting, not only moving away from the spirit of Level 1 and persevering in maintaining a costly and flawed transparency regime, but also setting the course for the EU to become an outlier while other jurisdictions move towards regulatory convergence around the UPI. The EU leads the way in driving forward standards globally. While a few stakeholders raised concerns about short-term implementation and transition costs, it is our view that those are of insufficient materiality to justify undermining the longer term EU strategy to boost the competitiveness and attractiveness of the CMU. II) Specific Comments on the draft DA The removal of the expiry date from OTC ISIN generation in IRS will eliminate the problem of rolling ISINs for this asset class, and we thus welcome the change. Using Boolean flags for non-standard tenors and forward starting products, instead of new ISINs for each non-standard tenor or forward starting date, will significantly reduce the instance of OTC ISINs which require to be managed. We also welcome this approach. In terms of other fields within the reference data, we do not understand why fields 19 to 30 in Table 1 need to be collected against an ISIN allocation. Mostly these fields will be fairly static, but they will introduce variables, which when combined with the variables arising from fields 1-14 will produce a significant number of combinations requiring a new ISIN, with knock-on implications for transparency and data quality. The inclusion of these fields as part of ISIN issuance does not make much sense, and we would rather see them removed. The more fields included in ISIN issuance the more the likelihood of error, and the greater the complexity of data management. Field 31 could be included but could be offered as another Boolean field between IMM and standard roll conventions. We note also that the UPI is included in both Table 1 and Table 2. Whilst we understand that the ANNA DSB (as sole issuer of OTC ISINs and UPIs) will generate a UPI as part of the ISIN creation process, the Commission needs to direct ESMA to include UPI as a separate reportable field outside the ISIN in RTS 23 reporting. This way UPI can at least be more easily leveraged for international comparisons. Also separate UPI inclusion in FIRDS via RTS 23 reporting ensures that EU regulators are in a better position in future to move from OTC ISIN to the globally agreed UPI. Whilst we recognise that this DA only covers products within transparency scope, we believe that, where relevant, a modification to ISIN should be made for all OTC derivative products within any reporting scope of MiFID II/MiFIR, in lieu of moving all reporting to UPI. We would therefore urge the Commission to use their empowerment in relation to transaction reporting to urgently advance this work and as a priority remove ISIN generation overhead in equity and FX swaps particularly.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

25 Apr 2024 · Energy Market

Meeting with Bart Groothuis (Member of the European Parliament) and European Policy Centre and

10 Apr 2024 · Sanctions

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Helena Hinto (Cabinet of Commissioner Kadri Simson), Jaan Mannik (Cabinet of Commissioner Kadri Simson), Peeter Kadarik (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

28 Feb 2024 · Presentation and discussion on BNEF Energy Transition Investment Trends

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Jan 2024 · Participants discussed in a broad sense the state of the European Union in a year of transition.

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

18 Dec 2023 · Benchmark Regulation

Response to Regulations specifying criteria and fees for the critical ICT third-party service providers in the financial sector

14 Dec 2023

We welcome the publication of the ECs draft Delegated Act on CTPP criticality criteria under DORA. We appreciate that the EC has proposed a more targeted approach integrating the provision of ICT services supporting critical or important functions as an underlying element for the criticality assessment on all sub-criteria. As the ESAs undertake this important work, we strongly recommend that even if critical designation is made at an entity or group level in line with DORA, the designation and subsequent oversight of CTPPs should be clearly targeted around those specific material services that are critical and the failure or disruption of which could adversely impact key regulatory objectives, including financial stability. This will ultimately affect the ESAs ability to focus effectively on the operational resilience of critical services when conducting the oversight. To implement the proposed two-step approach based on quantitative and qualitative sub-criteria, it will be vital for the credibility, effectiveness and smooth operation of the regime that the ESAs employ a documented, evidence-based criticality assessment of ICT providers. This would provide much needed clarity on the scope and day-to-day conduct of the oversight. Documented evidence of each criticality assessment will also help the ESAs maintain consistent standards across all in-scope ICT providers, ensuring transparency, fairness and efficacy. We would therefore expect the ESAs to provide detailed and documented evidence to the providers designated as critical explaining (i) how the quantitative and qualitative sub-criteria were applied as part of the criticality assessment and (ii) each of the underlying data points and analytical steps used to measure each of the proposed sub-criteria. We also note that the EC anchors the ESAs criticality assessment to the data provided by the financial entities registers of information, as well as any additional available data the ESAs may have at their disposal. While we welcome such clarification, we recommend ensuring that the ESAs assess the extent to which each financial entitys input is accurate, well-reasoned and appropriately documented. Firms may not always differentiate appropriately between critical services and non-critical services to a practicable degree and/or may not be in a position to provide adequate objective justifications, for example to determine the lack of alternative ICT services available and the difficulty of migrating a service from an ICT provider to another. Overall, should the financial entities provide assessments that are too general and/or not objective and evidence-backed, these should not be considered by the ESAs as relevant for the purpose of the criticality assessment. Finally, we have concerns on the determination of the degree of substitutability criterion. We believe that the EC approach to rely on the 10% threshold for the quantitative sub-criteria in circumstances where either (1) there are no alternatives or (2) it is "difficult to migrate or reintegrate an ICT service", will result in an unduly over-inclusive list of designated CTPPs, disproportionately increasing the regulatory burden on CTPPs, as well as diluting the effectiveness of the oversight. Further, we consider the absence of a definition of when it is "highly difficult to migrate an ICT service as problematic and lacking the necessary empirical evidence for the assessment to be accurate. Switching may be economic based on benefits outweighing costs even when switching is "difficult" in an absolute sense (e.g. high costs). Moreover, as such approach is to be applied both by financial entities for the quantitative assessment (sub-criteria 4.1 and 4.2) and by the ESAs for the qualitative assessment (based on DORA Article 31.2 (d)(i)), the lack of clarity on how these assessments should be determined could ultimately affect the evidence-based designation of CTPPs, as mentioned above.
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Response to Regulations specifying criteria and fees for the critical ICT third-party service providers in the financial sector

14 Dec 2023

We welcome the publication of the ECs draft Delegated Act on the CTPP oversight fees under DORA. We note that the proposed article 2 requires ICT third-party services providers designated as critical to provide the Lead Overseer with audited figures specifying the turnover for the purpose of the oversight fee calculation. Similarly, recital 4 states that "To ensure the accuracy of the financial information needed to calculate the applicable turnover, all figures provided by the ICT services provider should be audited ones". We would like to point out that an audit is a process around a financial statement of a defined legal entity. The scope of DORA is however much broader than one legal entity, therefore the concept of an audit of turnover would not be applicable to this type of process unless all EU data are ring-fenced into a specific legal entity (or group of legal entities, all audited), which is not how large corporate groups are typically structured. To ensure that the requirement of providing audited figures would take into account the heterogeneity and specificity of business models and legal structures of all firms, while maintaining the need for CTPPs to provide accurate financial information, we would recommend to also give the possibility to firms to use alternative procedures by internationally recognized audit standard setters, such as the Agreed Upon Procedures as an alternative type of audit firm engagement. This would provide a level playing field across firms while achieving the same outcome. These types of engagements are also governed by the IIASB's International Standard on Related Services (ISRS) 4400. We would therefore recommend the EC to amend the respective references in the draft Delegated Act as follows: Article 2.2 (subsequent references to be amended accordingly): Critical ICT third-party service-providers shall provide the Lead Overseer, on an annual basis in year n-1 with audited figures, or procedures performed by an assurance practitioner in accordance with a recognized audit standard setter, specifying the turnover referred to in paragraph 1 for year n-2. Recital 4: "To ensure the accuracy of the financial information needed to calculate the applicable turnover, all figures provided by the ICT services-provider should be audited ones, or have procedures performed by an assurance practitioner in accordance with a recognized audit standard setter".
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

5 Dec 2023 · COP28

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur) and European Digital Rights and ServiceNow

12 Jul 2023 · AI Act

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur)

26 Apr 2023 · MiFIR

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

19 Apr 2023 · VCMs and the Global Carbon Trust

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

27 Mar 2023 · Meeting on gender equality in finance

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

14 Mar 2023 · Briefing by Bloomberg New Energy Finance - overview on clean tech - supply chains

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans)

21 Feb 2023 · Cooperation in the context of the Global Covenant of Mayors

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

8 Feb 2023 · Organisation of an upcoming roundtable discussion - cooperation with BNEF on analytical support and sharing of studies

Meeting with Mairead McGuinness (Commissioner) and

13 Dec 2022 · Climate Data Steering Committee/pilot phase of the Net Zero Data Public Utility

Meeting with Věra Jourová (Vice-President)

30 Nov 2022 · Rule of Law

Meeting with Mairead McGuinness (Commissioner) and

16 Sept 2022 · Climate Data Steering Committee

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

1 Sept 2022 · Winter preparedness discussion with BNEF

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

15 Jun 2022 · EU Banking Package 2021

Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

9 Jun 2022 · Climate and energy transition

Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness), Nathalie De Basaldua (Cabinet of Commissioner Mairead Mcguinness), Peter Power (Cabinet of Commissioner Mairead Mcguinness)

9 Jun 2022 · Climate Data Platform

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

14 Feb 2022 · Digital operational resilience in the financial sector

Meeting with Valdis Dombrovskis (Executive Vice-President)

26 Oct 2021 · Next steps for the EU-US Trade and Technology Council

Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

26 Oct 2021 · EU-US Trade and Technology Council

Meeting with Valdis Dombrovskis (Executive Vice-President)

1 Oct 2021 · EU-US relations; Sustainable finance; Trade and Technology Council; Artificial Intelligence, Cybersecurity and Data skills

Meeting with Billy Kelleher (Member of the European Parliament, Rapporteur)

8 Sept 2021 · Digital Operational Resilience Act

Response to Supervisory fees and fines or penalty payments for DRSPs under ESMA supervision and the criteria for derogation

27 Aug 2021

We welcome the European Commission's decision to adopt a more proportionate approach to the one proposed in the technical advice as regards the use of audited H1 2021 revenue figures for calculation of the 2022 fees. Allowing DRSPs to rely on non-audited 2021 accounts as the basis for calculating/invoicing provisional fees is less burdensome, while it also ensures that ESMA receives the returns it requires in a timely manner. Once audited 2021 accounts are available to DRSPs, and have been submitted to ESMA without delay, a final invoice can then be issued for the difference based on the audited 2021 accounts. We note there has been no change of approach as regards the setting of fees. We have concerns that a few DRSPs paying above the minimum fee may end up paying disproportionately high fees given the small number of APAs/ARMs and relatively high ESMA cost base of around EUR 5 million per year. We continue to believe a higher minimum fee (for example, EUR 100,000 per data reporting service) and a maximum fee (for example, EUR 500,000 per data reporting service) would reduce the likelihood of disproportionately high fees for some DRSPs. It is important for the EC to understand that if fees for DRSP services are disproportionately high, then DRSPs may either withdraw from the market or pass their costs on to clients.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Bloomberg welcomes the European Commission’s (EC) proposal for a Corporate Sustainability Reporting Directive (CSRD). This marks an important milestone in the EU’s path to a sustainable economy, and Bloomberg remains committed to continuing to support the sustainable finance agenda as part of the EC’s global leadership on climate change. Bloomberg supports CSRD’s objective to enable the EC to adopt a mandatory set of sustainability reporting standards at the EU-level and expand the current scope of the Non-Financial Reporting Directive (NFRD) to incorporate over 49,000 companies into the reporting regime. This is key for financial market participants (FMPs) to sufficiently meet their obligations under existing EU legislative initiatives, such as the Sustainable Finance Disclosure Regulation (SFDR). Nonetheless, Bloomberg believes CSRD could be improved further. For instance, it is important to have a clear definition of double materiality in the legislative text to minimise uncertainty on what this would entail. This definition should align with the EU Taxonomy regarding the environmental impact of activities and be based on a minimum set of standards applicable to all companies and sectors. The new mandatory framework set by CSRD should also require companies to disclose the information needed by FMPs to produce their reports under the obligations of relevant EU sustainable finance legislation. For example, in-scope undertakings should be required to disclose in line with the principle adverse impact (PAI) regime as set out in SFDR. In order for asset managers to meet their SFDR obligations to report on PAI indicators, they need to have the data from CSRD companies to make these reports. Bloomberg supports the inclusion of EU subsidiaries of third country firms and all listed entities on an EU regulated market (except ‘micro’ enterprises) into the revised scope. However, it is important that reporting obligations are applied consistently across EU and non-EU entities, and at the parent level, to provide investors with a holistic insight into the firm’s sustainability credentials. In parallel, Bloomberg requests additional clarity on the equivalence regime in the Level 1 text, noting that any future equivalence decision should be based on high standards to ensure a level playing field amongst market participants. Bloomberg fully shares the EC’s stated objective to reach convergence on global sustainability reporting standards, and we believe the work of the Task-Force on Climate-related Financial Disclosures (TCFD) is ideal to serve as the foundational framework for the climate elements of the new EU sustainability reporting standards. The TCFD framework is already globally recognised and widely considered the key global framework for climate reporting, with over 2,300 supporters spanning 88 countries and including companies representing more than $24 trillion in market capitalisation. Many of the companies that will be covered by the CSRD already have experience reporting TCFD-aligned information. Through the forward-looking reporting recommended by the TCFD, companies must consider how they could be affected by, and ultimately meet, stated policy goals. In turn, such disclosure will allow FMPs to evaluate companies’ plans and progress over time. Reporting under the TCFD framework will also help FMPs deliver the climate change adaptation and mitigation objectives of the Taxonomy Regulation, as the EC aims to align CSRD with existing EU legislation. Bloomberg notes that the Task Force is currently consulting on a proposal to identify additional key metrics for disclosure by organizations in all sectors, provide guidance on the disclosure of transition planning, and to further emphasise forward-looking metrics for the financial sector. TCFD-aligned reporting can also be useful for many types of stakeholders under the lens of double materiality, such as Scope 1, Scope 2 and Scope 3 GHG emissions.
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Meeting with Mairead McGuinness (Commissioner) and

14 Jul 2021 · sustainable business summit interview.

Response to Supervisory data strategy

15 Jun 2021

Bloomberg welcomes the opportunity to provide feedback on the European Commission’s roadmap on the EU supervisory data strategy for financial services. We have set out in the attached document our key considerations on a number of co-ordinated sectoral and horizontal measures aimed at contributing to the overall objective of improving and modernising supervisory data collection.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Bloomberg welcomes the publication of the final draft Delegated Act for Article 8 under the Taxonomy Regulation. This marks a crucial step forward in the EU’s ambitions to reach the net-zero carbon economy. Bloomberg welcomes the European Commission’s decision to phase in Taxonomy reporting, starting with Taxonomy eligibility from January 2022 and reporting of Taxonomy alignment to follow the year after. Eligibility represents an important first step in completing a Taxonomy assessment. However, Bloomberg strongly disagrees with the exclusions of non-CSRD companies set out in the draft Delegated Act, especially large non-EU corporates. Such exclusions would obscure the true sustainable nature of an investment firm and will not provide end-investors and asset owners with the data they need to adequately assess the climate-related risks and opportunities fully associated with the investment. From a selection of European UCITS funds that market themselves as ‘green’, we see that 29% of the underlying bonds held are EU domiciled issuers, and 23% of underlying equity is from EU domiciled companies. This would mean that over 70% of companies invested in sustainable funds would not have their Taxonomy alignment computed. The Taxonomy was specifically designed to monitor all flows of capital within Europe, and those may include flows from non-CSRD companies. By limiting the reporting regime to EU CSRD companies, there is a risk of the Taxonomy failing to deliver its full potential to facilitate all avenues of capital towards the net-zero transition. Bloomberg recommends the European Commission to clarify the conflict within Article 8 for the treatment of financial undertakings not subject to Article 19a or 29a of Directive 2013/34/EU (“Accounting Directive”) and for the treatment of sovereign debt. We would also request the January 2025 review period, covered in Article 10, to extend to the treatment of derivatives. Bloomberg discourages breaking out financial reporting by: Article 19a or 29a of the Accounting Directive; financial and non-financial undertakings; EU and non-EU companies; and investment in sovereigns or derivatives. This will inevitably lead to complex reporting requirements, which in turn will discourage financial market participants (FMPs) from adopting the Taxonomy in investment workflows. The current level of segmentation in the draft Delegated Act places an undue burden on the reporting firm that is not consistent with the objectives of the Taxonomy Regulation. Furthermore, breakout by financial and non-financial, EU and non-EU investee companies can be obtained from other existing regulatory reports. Bloomberg believes that banks have a direct and fundamental role to play in directing capital towards sustainable outcomes. Their role as green capital mobilisers should be encouraged as they place capital into different sustainable lending activities, and the Green Asset Ratio (GAR) should act as a tool to facilitate this. However, the current GAR model under the draft Delegated Act is complex and may significantly inhibit banks’ capacity to understand the trigger points to raise their GAR, and investors will struggle to accurately compare factors. This will lead to a higher/lower GAR value across credit institutions. Bloomberg therefore recommends a simplified approach be taken whereby the GAR is designed to focus on the banks’ operations that are relevant to fostering capital towards Taxonomy-aligned activities, namely lending. Bloomberg finds limited value in including both off-balance sheet operations and the trading book at this time, though we would support a review of this in January 2025.
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Meeting with Mairead McGuinness (Commissioner) and

23 Apr 2021 · Green finance

Meeting with Mairead McGuinness (Commissioner)

21 Apr 2021 · Power of global capital markets in the fight against climate change.

Meeting with Thierry Breton (Commissioner) and

9 Mar 2021 · COVID vaccine production ramp-up

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Stichting European Climate Foundation

11 Feb 2021 · online keynote speech at the European Climate Foundation and Bloomberg Philanthropies event on Countdown to Net Zero (on renewable energies)

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

20 Oct 2020 · Virtual meeting on climate, environment and recovery

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

Bloomberg L.P. welcomes the opportunity to provide feedback on the proposed Delegated Act for the Taxonomy Regulation and its integration into non-financial reporting. We see it as the cornerstone to the EU's Sustainable Finance Action Plan, which we fully support. We believe this will encourage greater disclosure of important environmental and social data attributes over time and encourage the right conversations between an investment firm and the corporates they invest in. We fully support greater transparency and the use of a common language when making environmental investment claims. To be successful we think NFRD should: 1) Include clear, concise and appropriately detailed description of the data that a corporate is expected to report in order to satisfy their investors' needs under the Taxonomy regulation; 2) Provide appropriate support, through Q&A facilities, to allow the corporate to adequately and accurately disclose their taxonomy alignment; 3) Encourage and explain the difference between entity and activity level disclosure needed to satisfy the Taxonomy Regulation; 4) Bloomberg L.P. would recommend alignment with the Task Force on Climate-related Financial Disclosures (TCFD) framework, notably for companies wishing to make a claim that they substantially contribute to climate change adaptation. The TCFD’s 11 recommended disclosures provide a useful and already widely accepted framework for climate-related financial disclosures. Validating that the investee has conducted a climate risk assessment and is suitably monitoring and mitigating any climate related risks would be a key component of demonstrating long-termism in investment practices. We recognise and support the ambitious plans and multiple regulatory tools being employed by the European Commission to serve the Sustainable Finance Action Plan. We would ask that the European Supervisory Authorities and the European Commission develop and publish a clear overview of how the SFDR, the Taxonomy Regulation and future amendments such as those proposed to the Non-Financial Reporting Directive will work in complement to one another and a summary of all data points required.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans)

3 Aug 2020 · EU initiatives in the area of just transition

Meeting with Frans Timmermans (Executive Vice-President)

6 Jul 2020 · Green Recovery and energy sector transition in crisis times

Meeting with Per Haugaard (Cabinet of President Ursula von der Leyen) and Gates Foundation and

30 Jun 2020 · Global Goal Unite event

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

19 Jun 2020 · Preparation of EVP Timmermans speech at Bloomberg event

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

15 Jun 2020 · On-going studies by Bloomberg New Energy Finance in the area of just transition, hydrogen and renewables

Meeting with Frans Timmermans (Executive Vice-President)

15 Apr 2020 · Expected impact of Corona crisis on clean energy investments, key drivers of underpinning market evolution and future perspectives?

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

21 Feb 2020 · Smart sector integration and offshore wind initiative

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

27 Jan 2020 · European Green Deal

Meeting with Frans Timmermans (First Vice-President)

24 Sept 2019 · Sustainable development and climate cooperation

Meeting with Christoph Nerlich (Cabinet of Commissioner Marianne Thyssen)

10 Sept 2019 · Meeting with Lionel Laurent on EGF and ESF

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

8 May 2019 · Ocean Governance, Sustainable Business Summit

Meeting with Dominique Ristori (Director-General Energy)

6 May 2019 · the role of cities in driving the clean energy transition globally

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

6 May 2019 · Sustainable finance.

Meeting with Valdis Dombrovskis (Vice-President) and

10 Apr 2019 · Sustainable Finance

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

10 Jul 2018 · Sustainable Finance

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

22 May 2018 · sustainable finance, equivalence

Meeting with Carlos Moedas (Commissioner) and

22 May 2018 · Exchange on Research and Innovation priorities

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

22 Mar 2018 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Pierre Moscovici (Commissioner) and

25 Jan 2018 · discussion on EU and US political and economic outlook

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

25 Jan 2018 · Sustainable Finance and FinTech

Meeting with Jyrki Katainen (Vice-President)

25 Jan 2018 · CMU + EU economic outlook

Meeting with Phil Hogan (Commissioner)

8 Dec 2017 · Interview

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

4 Oct 2017 · Meeting to share the latest research results on electric vehicles and battery costs.

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

4 Oct 2017 · Electric vehicles; batteries