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CLIMCOM Berlin - ClimateCompany - the private institute for climate research and training

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Gegenstand des Unternehmens ist die Förderung des Klima- und Umweltschutzes.

Lobbying Activity

Meeting with Sarah Nelen (Head of Unit Environment)

10 Oct 2025 · Sustainable finance and environmental policy

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

5 Sept 2025 · Review of the SFDR

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

12 Jun 2025 · CSRD/ESRS revision

Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

Climate & Company welcomes the opportunity to contribute to the Commissions call for evidence. The high-level recommendations below build on our feedback to the 2023 targeted consultation and our 2024 white paper Transition products Conceptual Clarity & Implementation Guidance, which demonstrates that robust transition criteria can coexist with competitive risk-adjusted returns in public equity portfolios. A) In line with others, we suggest developing specific, criteria-based categories and retiring the Article 6, 8 and 9 structure. The current framework has evolved into a labelling system (light-/dark-green) that lacks clarity or minimum safeguards. Article 8, in particular, has become overinclusive, capturing the vast majority of products marketed as sustainable, limiting meaningful differentiation. Research from 2DII (2023) shows that retail investors primarily seek (i) measurable positive impact and (ii) value alignment - neither of which are explicitly supported by the current categorisation. In addition, the SFDR does not distinguish between investor impact and investee company impact - an essential differentiation for understanding real-world outcomes. B) These categories should be complemented by minimum criteria that act as entry points. We propose introducing at least two clearly defined categories: one for sustainable products and one for transition products - consistent with the direction proposed by ESMA for fund naming. A third, more flexible category (e.g. ESG strategy or environmental and/or social characteristics) could be considered to accommodate a broader range of responsible investment approaches. Minimum criteria are essential to create a coherent baseline and to provide retail and institutional investors with confidence. At the same time, market participants should remain free to go beyond these baselines and adopt more ambitious strategies. C) Specific minimum criteria for the transition category. Our white paper puts forward a tested proposal for transition products that strikes a balance between credibility and feasibility. The approach is based on the following elements: - General exclusions: Align with the EU CTB exclusions, including controversial weapons, tobacco, and persistent violations of the UNGC/OECD guidelines. - Conditional exclusions for fossil fuel companies: Rather than excluding them by default, fossil fuel companies should only be eligible if they meet credible transition criteria: e.g. no expansion of fossil fuel infrastructure and a credible, transition plan. - Positive screening based on forward-looking criteria: Companies must have a verified science-based target to become eligible. - 80/20 portfolio composition: At least 80% of the products net asset value should meet the minimum criteria outlined above. A limited flexibility pocket (up to 20%) is permitted but must not undermine the overall strategy or objectives. - Engagement and stewardship requirements: For transition products, particularly in public equity markets, investor stewardship is essential to support real-world impact. Products should be required to implement a formal engagement strategy that includes measurable, time-bound transition objectives, a clear prioritisation of target companies, and a structured escalation policy if engagement goals are not met. This structure has been tested using real-world data, showing that it is possible to construct financially competitive portfolios while maintaining environmental ambition. Our simulations also demonstrate that resulting portfolios achieve benchmark-like performance with limited tracking error. We remain available to support further technical work and stand ready to contribute to the design and pilot testing of future SFDR product categories.
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Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

21 May 2025 · Exchange of views on Climate and company’s ongoing work

Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

20 Mar 2025 · Omnibus simplification, ESRS

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

12 Mar 2025 · CSRD Omnibus

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

10 Feb 2025 · Sustainable Finance framework

Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

28 Jan 2025 · Simplification of sustainability reporting

Meeting with René Repasi (Member of the European Parliament, Rapporteur for opinion)

22 Jun 2023 · EU-Lieferkettengesetz/ Corporate Sustainability Due Diligence Directive - Staff Level

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and FTI Consulting Belgium

13 Oct 2022 · Introductory meeting

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

8 Apr 2022 · Green Deal and European Semester

Response to Setting out common indicators and detailed elements of the recovery and resilience scoreboard

25 Aug 2021

Climate & Company (Germany): response to the public consultation on the Recovery and Resilience Facility Scoreboard Climate & Company welcomes the opportunity to provide feedback regarding the draft delegated regulation setting out the contents of the European Commission’s Recovery and Resilience Scoreboard. 1. The explanatory memorandum of the proposed delegated acts outlines that monitoring of progress under the RRF through the Scoreboard does not preclude the use of other tools to monitor progress by Member States in the context of the European Semester, such as the Social Scoreboard. The proposed RRF Scoreboard would benefit if the links to and overlaps with other scoreboards and governance structures, like the Macroeconomic Imbalance Procedure Scoreboard or the Social Scoreboard, were clarified. The Commission requires Member States to align their RRF plans (RRPs) with their National Reform Programmes (European Semester and country specific recommendations) and their National Energy and Climate Plans (NECPs), amongst other plans. The NECP guidelines contain a wide range of indicators that Member States can base themselves on when reporting their progress on their NECP. Users of these scoreboards and indicators would benefit if the purpose and use of the different scoreboards were made more clear. 2. According to the RRF regulation, social expenditures should be part of the performance reporting system of the Facility. The Commission should clarify if the current indicators of social expenditures will be modified or revised after the consultation to define a methodology for reporting social expenditure. 3. The Scoreboard is to display the progress of the implementation of the national RRPs in each of the six pillars of the Facility, and in relation to the common indicators. We welcome the inclusion of the milestones and targets from the national RRPs. However, Member States define milestones and targets in different ways. The delegated act does not clarify how it will deal with these differences. It seems that the measurement of milestones and targets will exclusively rely on self-reported information. By indicating the fulfilled milestones and targets as a percentage of the total number of milestones and targets, the Commission is not reflecting on the objectives that these milestones and targets aim to reach, their scale and their relative importance. We consider that this quantitative indicator disregards the importance and quality of the targets. It will be difficult to draw sound conclusions from the percentage of fulfilled milestones and targets alone. Art. 1(a) should be changed to: “by listing all milestones and targets, irrespective if they have been satisfactorily fulfilled or not”. In addition, the scoreboard should propose a scale to measure the fulfillment of milestones and targets, either ordinal, interval or numerical. A simple binary assessment as currently proposed (“satisfactorily fulfilled or not”) does not reflect the complexity of the milestones and targets. A more detailed scale to measure progress on reforms is highly recommended. To ensure a coherent and consistent policy implementation across various governance structures and strong inter linkages between the RRF and the European Semester, Climate & Company suggests amending Art. 1(a) to: “Member States should report and outline how the fulfillment of milestones and targets contributes to the implementation of relevant country specific recommendations”. .... (please see full response to public consultation attached below)
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