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Deloitte Services & Investments

Deloitte delivers services in audit, accounting, tax and legal, consulting, financial advisory services, and risk advisory services to public and private clients spanning multiple industries.

Lobbying Activity

Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

We identify several matters that could enhance the usefulness of the information provided under SFDR and the effectiveness of implementation, and reduce its complexity in line with its ultimate objective to enhance the transparency of sustainability information for the end investor. For details please see the attachment. 1. Reduce the complexity and administrative burden of the PAI statement at entity level. Due to the large and complex PAI disclosures, the objective to inform retail and institutional investors might not be met. We recommend the ESAs consider reviewing the whole list of KPIs and take steps towards determining a clear, understandable, and useful set of PAIs that are easy to compare between entities. 2. Align KPIs and calculation methodology with other regulations/standards. We encourage greater interoperability between EU regulations to help ensure that entities are not re-quired to prepare multiple sets of reports, or a plethora of different metrics under different standards. We recommend that the SFDR is revised to be aligned with the relevant revisions to the CSRD and the ESRS, EBA Pillar 3 and the EU Taxonomy regulation. We also recommend that the EC should consider formally embedding FAQ 90 of the FAQs on the interpretation of certain legal provisions as regards sustainability reporting into the SFDR. The methodologies for calculating, processing, and consolidating KPIs should be coherent to ensure usability of information and consistency and comparability between SFDR, CSRD and the EU Taxonomy regulation. 3. Reflect the Omnibus proposals and the impact on data availability in the revisions to SFDR. The investment universe of FMPs can include a wide range of different asset classes, sectors and geographies. This can include exposures to small and medium-sized companies, alternative investments, and investments outside the EU. We recommend that the SFDR should clearly indicate how FMPs should address the resulting data gaps (e.g. data coverage ratio, estimates). The revisions should provide clear guidance on how FMPs should address data challenges within illiquid asset classes. 4. Align the disclosures on the voluntary reporting standard and the value chain cap proposed for the CSRD. The SFDR should address the trickle-down effect arising from its disclosure requirements on companies not falling under the CSRD. 5. Redesign the product design of SFDR. Clarity is required on the primary objective of the SFDR: is it intended to be an additional disclosure obligation or a labelling scheme? If intended to be the latter, we suggest introducing an alternative concept of product features that financial market participants can combine in the design of products. 6. Reduce the complexity of product disclosures. The current product disclosures are perceived as too complex. We recommend reducing their complexity for pre-contractual disclosures, website publications and period reporting. 7. Differentiate between product types and investor types. The current rules of the SFDR do not sufficiently differentiate between the individual characteristics of the underlying financial products. FMPs could be granted more flexibility in the way that they provide the information to their clients. 8. Differentiate between retail clients and institutional clients. The granularity of disclosures is too complex for retail clients. Their information needs should be better reflected in the SFDR requirements. 9. Include the ESMA Guidelines on Fund Names. We recommend including the ESMA Guidelines on Fund Names into the SFDR. The exclusion criteria of the PAB and the CTB could be introduced as potential product features. 10. Adjust the definition of sustainable investment. The current definition of sustainable investments is too vague and leaves too much room for interpretation and, hence, may as a result increase the risk of greenwashing. We recommend clarifying the definition of sustainable investment in the SF
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Meeting with Michael McGrath (Commissioner)

27 Mar 2025 · Exchange on range of issues related to Commissioner’s portfolio including simplification, digital and consumer protection.

Meeting with Manuela Geleng (Director Employment, Social Affairs and Inclusion)

24 Mar 2025 · Exchange of views on skills development initiatives

Response to Rationalisation of reporting requirements

28 Nov 2023

We welcome the aim of the Commission to improve the competitiveness of EU businesses in global markets and support the Commissions initiative to rationalise reporting requirements. We welcome the request for feedback, ideas and input to identify further opportunities for streamlining reporting requirements in EU legislation without undermining the policy objectives. We support better regulation and encourage the Commission to undertake similar reviews on a periodic basis, to capture and share evidence publicly and allow informed debate on the development of EU policy and legislation, given its complexity, technical content and constant evolution. These reviews should be followed by streamlining of EU reporting requirements to ensure that they are proportionate and effective. Our response (attached) focuses mainly on the need to streamline the legislation that forms part of the EU sustainable finance package including the new sustainability reporting requirements in the Corporate Sustainability Reporting Directive (CSRD) which require companies to use the recently adopted European Sustainability Reporting Standards (ESRS); the EU Taxonomy Regulation; and the Sustainable Finance Disclosure Regulation (SFDR). Our recommendations for streamlining this legislation are intended to enable standards and regulations that support decision-useful information, encourage entities to integrate considerations of people, the environment and prosperity for society into the core of the business, and better support the flow of capital to long-term, sustainable business.
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Response to VAT in the Digital Age

2 Apr 2023

Please find attached the feedback and comments of Deloitte on the ViDA proposals.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Dear Mr. Berrigan, On behalf of the Deloitte firms in the European Union, we are pleased to provide feedback on the draft EU Taxonomy Article 8 Delegated Act. Once completed with further clarifications, the Delegated Act has the potential to provide transparency in the market through disclosures, to guide environmentally sustainable investment and contribute to implementation of the EU action plan for financing sustainable growth, thereby contributing to the success of the European Green Deal. We have provided, in an appendix to this letter, comments and suggestions related to specific points of the draft Delegated Act. Please find below some key elements for your consideration. For the success of the information to be reported, it is important to ensure that relevant information is made available through reliable and comparable disclosure by companies. To achieve this, the disclosure requirements should be sufficiently precise, clear and understandable in order to be implemented consistently and to be auditable. The draft Delegated Act includes some requirements where further clarity is needed. In particular, we consider that the following aspects are of prime importance and need to be addressed to ensure implementation feasibility, consistency, reliability and auditability: 1. Timeline and requirements in the transition period for financial undertakings: the lack of available data from non-financial undertakings will mean making significant estimates, thereby creating challenges with respect to their reliability. In addition, we note that the basis for the KPIs for banks will be the consolidated prudential reporting, which may be significantly different from the consolidated financial statements (that latter one being subject to an audit but not necessarily the former, at least in some jurisdictions). We also have questions about the underlying consistency followed for the determination of some KPIs, such as derivatives or the trading book, noting that those transactions do not finance the core business of non-financial undertakings generally. 2. Timeline for the transition period: should the five years of comparative information continue to be required in the final Delegated Act, we would suggest a progressive implementation of the disclosure of historical information, beginning with providing one year only for 2021 and the additional annual data made available as each year passes, so as to reach five years of historical data by 2026. 3. Definition of an “economic activity”: the types of “economic activities” that shall be considered require further clarification. This would entail explaining how to address activities carried out by an undertaking that do not generate turnover, for instance for activities listed in the Delegated Act on Climate Change Adaptation that are not “enabling”. 4. Definitions of CapEx and OpEx: further clarification is required on investments and expenditure to be considered, in particular which CapEx related to assets and processes that are associated with Taxonomy-aligned economic activities shall be included in the numerator. For OpEx, further clarity is needed on the nature of costs to be included in the denominator, and whether there should be consistency with those included in the numerator. The information to be provided under the Taxonomy regulation is quite new and the disclosure requirements have been developed in a relatively short-time frame. Once the final Delegated Act will be adopted, there will undoubtedly be a need for further explanations. We recommend the European Commission to set-up a mechanism to gather and address questions. If you have any questions or you would like to discuss our comments, please contact Laurence Rivat, EU Corporate Reporting Policy Leader, on +33 1 55 61 67 60, or Pablo Zalba, Managing Director EU Policy Centre, on +34 91 438 19 08. Yours Sincerely, Laurence Rivat EU Corporate Reporting Policy Leader Pablo Zalba Managing Director EUPC
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

11 Jan 2021 · AML enforcement, AML legislative package

Meeting with Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

7 Jan 2020 · World Economic Forum

Meeting with Manfred Kraff (Director-General Internal Audit Service)

1 Oct 2018 · Discussion on challenges related to the assessment and audit of large public projects

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Deloitte LLP

11 Apr 2018 · Audit

Meeting with Marlene Holzner (Cabinet of Vice-President Günther Oettinger)

18 Jan 2018 · Euronews

Meeting with Jos Delbeke (Director-General Climate Action)

17 May 2017 · Sustainability and mobility

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

9 Mar 2017 · global transport lead and our EMEA lead for Infrastructure and Capital Projects

Meeting with Maarten Verwey (Director-General Structural Reform Support)

22 Feb 2016 · Introductory visit

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

8 Jul 2015 · Customs Code in the EU

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen), Stefaan Hermans (Cabinet of Commissioner Marianne Thyssen)

19 May 2015 · Employment and EURES

Meeting with Nadia Maria Calvino Santamaria (Director-General Budget)

2 Feb 2015 · ABAC Framework Contract