Dutch Fund and Asset Management Association
DUFAS
Sinds 2003 zet DUFAS zich in voor een gezonde vermogensbeheersector in Nederland.
ID: 220401741522-57
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
5 Dec 2025
The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the European Commissions Call for evidence for review of the Climate and Environmental delegated acts. In our response, we outline various elements of the framework that, from a global investor perspective, would benefit from further improvement. This concerns a.o.: - Improving the usability of the framework for non-EU assets; - The limited added value of the minimum safeguards for renewable energy projects within the EU; - Simplifying the assessment of Taxonomy alignment for certain private market investments; and - Strengthening alignment of the Taxonomy indicators for real estate by referencing CRREM. Please find our full response attached. We are available should have you have any questions or comments.
Read full responseMeeting with Gerben-Jan Gerbrandy (Member of the European Parliament)
27 Nov 2025 · SIU / SFDR
Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)
6 Nov 2025 · SFDR
Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)
5 Nov 2025 · Securitisation
Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
16 Oct 2025 · SIU and SFDR
Response to Revision of EU rules on sustainable finance disclosure
30 May 2025
The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the European Commissions Call for evidence on revision of the rules on sustainable finance disclosures, published 2 May 2025. The Call for evidence acknowledges the broad market support for improving the Sustainable Finance Disclosure Regulation (SFDR). It echoes our earlier feedback, in which we expressed our view that the current SFDR framework is not achieving its primary goals and that a number of elements should be adjusted in order to be better able to achieve the goals set by the SFDR. In attached response to the Call for evidence, we wish to highlight several of our key recommendations and ask you to consider these in the upcoming revision. In short, our key recommendations are: - The revision of the SFDR should be guided by data relevance and availability. This should be focused on one comprehensive set of the most critically relevant datapoints, that are integrally aligned within the entire Sustainable Finance Framework. Consequently, a sufficient level of availability of relevant data should be supported by the on-going review of the Corporate Sustainability Reporting Directive (CSRD) and the related European Sustainability Reporting Standards (ESRS). - Standardized sustainability disclosures should apply to all financial products, to enhance comparability and to create a level playing field between all products. We also underline the importance of both consumer and industry testing of any revised disclosure requirements. - Product categorization should be fit to cater to all products under the SFDR and not imply communication restrictions for uncategorized products. This is of crucial relevance to long-term, multi asset products like pension schemes. These products will most likely only be able to meet the thresholds of a category for parts of their portfolio. - Transition finance needs to be supported by the SFDR, with a key focus on the energy and climate transitions, but with the option to broaden the approach to other environmental or social transitions. We also ask the Commission to recognize that there are current market practices that include in transition finance also those economic activities that enable and support the energy and climate transitions. This is crucial in order to avoid that these important investments are discouraged because of how the categories are designed. - Coherence between all parts of the Sustainable Finance Framework is crucial to support consistency of application and to avoid reporting and administrative overlap. Key concepts such as 'sustainable investment' need to be harmonized and clearly defined. We also ask the European Commission to confirm that mandatory sustainability-related requirements for financial products and services are covered only by targeted financial sector legislation, which, in turn, should be fully aligned with the requirements targeting corporate transparency and behavior in the real economy.
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
26 Mar 2025
The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to provide feedback on the proposed amendments to various Commission Delegated Regulations regarding simplification of certain elements under the Taxonomy Regulation. We support efforts by the European Commission to simplify and increase the coherence of the EU Sustainable Finance Framework. As regards the Omnibus I proposals, and specifically with regard to amending the Taxonomy Delegated Acts, we support simplification proposals that could facilitate broader reported alignment with the Taxonomy and thereby support the goals of the sustainable finance framework. To this end, we support the introduction of a materiality threshold and a comprehensive review of the do no significant harm-criteria, as this should make it easier for companies to increase reported alignment and focus their efforts on the most relevant activities. This will in turn facilitate investor consideration of, and reporting on, the alignment of these economic activities. However, there are also certain aspects to the proposals for simplification that could benefit from further improvement. In general, we would like to point out that simplification is most effective if the proposed amendments are themselves not overly complex but instead lead to clarity both in terms of methodology and in definitions. For example, further clarity needs to be provided around the criteria and conditions for reporting on partial alignment. Additionally, alignment of the proposed amendments with the reporting requirements under the SFDR (including alignment of the do no significant harm-tests under the SFDR and the Taxonomy) would have to be taken into account as well. In the attached consulation response, we present our feedback to selected elements of the proposed amendments that might benefit from further improvement.
Read full responseMeeting with Astrid Dentler (Cabinet of Commissioner Wopke Hoekstra), Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra)
12 Mar 2025 · Exchange of views on the Savings and Investment Union
Meeting with Auke Zijlstra (Member of the European Parliament)
24 Sept 2024 · Asset management
Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and JPMorgan Chase & Co. and
11 Sept 2024 · Retail Investment Strategy
Response to Environmental, social and governance (ESG) ratings and sustainability risks in credit ratings
1 Sept 2023
Executive summary DUFAS and its members welcomes the proposal for regulation on the transparency and integrity of ESG rating activities. ESG ratings and ESG data are important for asset managers. DUFAS and its members emphasize therefore the need for a well-functioning ESG ratings market that provides relevant, reliable, and comparable ESG ratings. We support requiring transparency on methodologies, the purpose of the ratings such as performance work-based or outcome-based also in the name of ratings, the use of underlying data sources, and any engagement with rated entities. However, it is important that compliance costs remain low in order to make sure that ESG ratings are affordable and available for a competitive market price for European asset managers, in particular for mid to small managers. Hence, a too stringent authorization regime for ESG rating providers may lead to an increase of compliance costs, also possibly caused by a reduction of competitiveness in the EU market for ESG rating providers. The use of ESG data and data products is growing in importance and asset managers face similar issues related to transparency. However, we believe that an effective implementation of the European Single Access Point (ESAP) would sufficiently cover such issues for ESG data. A similar treatment as ESG ratings, such as a full authorization scheme, would be inappropriate as it would raise the barrier for crucial innovation and new entrants in the ESG data products market. However, we are supportive of the application of certain transparency rules to data vendors similar to ESG rating providers. For financial market participants, it is essential that ESG data vendors are transparent about their fees, the source of the data and potential methodologies used. Data on companies may be derived from and based on (i) public information sources, (ii) non-public sources, but obtained directly from the companies via bilateral discussions and interviews, and (iii) estimates by the ESG data provider itself. We welcome the exemption for ESG ratings produced by regulated financial undertakings that are used for internal purposes or for providing in-house financial services and products. However, we believe that this exemption should be clarified. The same applies to the question whether investment research providers that also may include ESG related opinions or qualifications on companies as part of their investment research report fall within the scope of the regulation. Please read our position paper as attached for a full response.
Read full responseResponse to Retail Investment Package
28 Aug 2023
Executive Summary DUFAS welcomes the opportunity to respond to their extensive reform proposal of the EU legislative framework for retail investments, the Retail Investment Strategy (RIS) as published on 24 May 2023. We strongly support the objective of the RIS to boosting better access of retail participation in the financial markets. We do appreciate the European Commission's comprehensive work in this field. The proposal by the European Commission entails several proposals that should contribute to more retail participation in the capital markets. Some of the proposed measures are however quite far-reaching and could however lead to unintended side-effects especially regarding new and emerging business models. However, some of the elements of the RIS proposal could also cater for improved retail participation. More retail participation should be gained based on (i) transparency and (ii) trust. Value for Money Our main concern relate to the Value for Money concept and the benchmarking mechanism set forth in MiFID product governance rules and undue costs rules in AIFMD and UCITS. We believe that the Value for Money concept, the way it is proposed by the European Commission, could effectively be perceived as price interference, even if it has not been intended as such. As a result we are concerned about maintaining a diverse product landscape suited for catering the wide range of possible (retail) investments needs. We are also concerned that the proposals do not sufficiently recognize the significant structural differences between different markets what may work in the Dutch market may not be applicable in other markets or indeed vice versa. Costs benchmarking for transparency purposes We have concerns about the benchmarking included in the European Commission proposal and the potential price interference mechanism that comes along with it. However, if done properly we do see merit in costs benchmarking as a transparency tool for the retail investor. More transparency creates trust. We therefore support any establishment of such benchmarking for this purpose only provided that (i) benchmarking only includes costs, not performance which as a concept should be represented separately, and (ii) establishment of benchmarks is done with utmost due care and with input from and dialogue with the investment industry. We acknowledge the complexity and challenge of creating relevant benchmarks. Benchmarking and maintenance thereof will necessitate a solid governance process including appropriate IT governance. Our experience of establishing a multi-stakeholder, multi-national data delivery mechanisms across multiple third party IT systems such as those run by FinDatEx for MiFID 2 or PRIIPs reporting underlines the importance of allowing sufficient time for design, testing and delivery, Undue costs We disagree with the proposed compensation rights granted to retail investors for undue costs. We believe that full transparency via a benchmarking system as proposed is a far better way to deal with retail investors rights rather than such compensation rights. Simplified investment services We support any initiative of the European Commission ensuring that suitability and appropriateness tests are better adapted to retail investors. Limiting suitability and appropriateness requirements for certain investment services and financial products could have a positive effect on access of retail clients to capital markets. This could be defined as so-called simplified investment services concept, services that create better and easier for retail clients. For such purpose, we have outlined specific proposals to this effect as elaborated in our position paper. We refer for a full response, including our recommendations, to our comprehensive position paper on the RIS as attached.
Read full responseResponse to European Sustainability Reporting Standards
7 Jul 2023
The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the European Commission consultation as we would like to emphasize the importance that PAI indicators prescribed under SFDR should be mandatory in the ESRS in order for asset managers to fulfill their SFDR reporting obligations. Include mandatory reporting of PAI indicators DUFAS and its members support and encourage the explicit requirement in the Corporate Sustainability Reporting Directive (CSRD) that the European sustainability reporting standards (ESRS) should be coherent with other legislation, in particular the Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy. However, we are concerned with the recent changes removing the mandatory disclosure of principal adverse impacts (PAI) indicators. We believe that the proposed reporting obligations of companies under CSRD and ESRS are not consistent with reporting obligations financial market participants (FMPs) have under SFDR. Therefore, we emphasize the importance that all PAI indicators prescribed under SFDR should be mandatory in the ESRS in order for FMPs, such as asset managers, to fulfill their SFDR reporting obligations and more importantly - contribute to realizing the European Green Deal. Should PAI indicators remain subject to materiality assessment under ESRS, the treatment of PAI indicators in SFDR should be harmonized with ESRS The main driver behind the required alignment is availability of data in order to allow meaningful reporting by FMPs for the various stakeholders. In case the European Commission chooses to maintain the materiality principle for companies in relation to reporting on inter alia the SFDR PAI-related indicators, this option should be also reflected in the requirements applicable to FMPs under SFDR. Concretely, as part of the PAI statement and Do No Significantly Harm (DNSH) test for sustainable investments, FMPs should as a minimum be allowed to take into account the materiality of PAIs as disclosed by an investee company. In addition, FMPs should also be allowed to do their own materiality assessment of the investee companies. Furthermore, in order to facilitate FMPs and in order to provide transparency and consistency for various stakeholders including FMPs companies, in any event, should be required to disclose why a PAI indicator is considered immaterial and periodically reassess the materiality. This requirement will provide transparency to these stakeholders and ensure consistency in reporting Additional phase-in leads to further delay in necessary data required by investors FMPs under SFDR must already disclose PAI statements despite challenges in available data and robust estimates. The additional phase-in periods in the ESRS would further exacerbate and extend the current data challenges by several years. Delays in reporting will also affect information on Scope 3 greenhouse gasses emissions, biodiversity and social standards and therefore have a negative impact on realizing our goals under the European Green Deal. If the European Commission decides to maintain the proposed phase-in, it should make sure that this is adequately reflected in the SFDR reporting requirements for FMPs. Clarity needed regarding ESRS exclusion of assets under portfolio management CSRD states that it does not apply to financial products mentioned in the SFDR, i.e. AIFs and UCITS. However, it is not clearly stated that assets under portfolio management, a service rather than product, are excluded from CSRD and ESRS disclosures. It would be inconsistent to include assets under portfolio management under CSRD/ESRS reporting, since they are also covered as a financial product by SFDR reporting (like AIFs and UCITS). We therefore believe it should be explicitly stated that these assets are also excluded from reporting under CSRD/ESRS.
Read full responseMeeting with Esther De Lange (Member of the European Parliament)
23 May 2023 · Introductory meeting - APA
Response to Initiative on EU taxonomy - environmental objective
2 May 2023
We believe that the EU Taxonomy is an important and useful supporting tool for asset managers pursuing environmentally sustainable investments. Although the EU Taxonomy affects asset managers less directly than SFDR, several key challenges within the Sustainable Finance Framework could be tackled with an effective implementation of a science-based Taxonomy. As the Dutch Fund and Asset Management Association (DUFAS), we welcome the opportunity to respond to the European Commissions consultation on the EU Taxonomy Delegated Acts as published on 5 April 2023. New activities and criteria should be science-based To achieve a green and sustainable economy, the EU needs a large-scale transition involving many sectors and economic activities. To ensure that the EU Taxonomy is an objective classification of green activities, we urge that the inclusion of new activities and technical screen criteria are science-based. This is particularly important for activities whose inclusion may be more controversial such as air transport and manufacture of plastic packing goods. Green activities and targeting high pollution sectors are both important but could be more distinct The EU Taxonomy consists of a broad array of activities that can be labelled green. However, we note that this blurs the distinction between intrinsically green activities and activities focusing on strongly reducing negative impacts. Both are important for the transition to a sustainable economy, but acknowledging the difference within the Taxonomy could further clarify and substantiate the inclusion of different activities. This could be achieved within the Taxonomy by, for example, using the categories of enabling and transitional activities for activities focusing on reducing negative impacts. Agriculture as missing economic activity The activities related to the protection and restoration of biodiversity and ecosystem are highly limited, with agriculture as the main activity not included in the Taxonomy. Although currently a large source of negative environmental impacts, it is highly relevant as a potential solution to multiple objectives. We again strongly emphasize the importance of science-based criteria, especially for agriculture, to ensure the effectiveness of the EU Taxonomy.
Read full responseResponse to Alternative Investment Fund Managers – review of EU rules
23 Mar 2022
DUFAS (Dutch Fund and Asset Management Association) welcomes the European Commission’s (EC) review of the Alternative Investment Fund Management Directive (AIFMD) and its aim to set out targeted improvements to key provisions in the current framework. DUFAS however, wishes to emphasize that although the proposed amendments to the AIFMD do not introduce wholesale changes to the framework, there are some important amendments to key areas that warrant close attention.
These relate to inter alia (i) our request to expand the ancillary services that AIFMs can provide with client order execution, (ii) our concerns with regard to the proposed amendments regarding Liquidity Management Tools (LMTs) and the possible consequences of too much of an interventionist approach by ESMA when establishing the level 2 specifications, (iii) the impact of the proposed provisions on Loan Originating Funds (LOFs) which will have a disastrous impact on the Dutch micro-finance and green funds, - funds that already implement the most important Capital Markets Union (CMU) and Sustainable Finance objectives in practical terms, and have been doing so for quite some years already, (iv) our suggestion to exclude intra-group delegation from the scope of the delegation provisions, (v) our proposal with regard to the proposed amendments to the (supervisory) reporting requirements for a better coordination between relevant authorities in order to prevent the same data being requested by different supervisors, (vi) removal of the proposed stipulations regarding disclosure as they already are covered by existing disclosure requirements for AIFs and (vii) finally, given the practical consequences of the proposed changes, the need for grandfathering provisions. Please see our feedback in full detail in attached consultation response.
Read full responseResponse to EU single access point for financial and non-financial information publicly disclosed by companies
24 Feb 2022
DUFAS supports the development of a European Single Access Point as it will improve data availability for asset managers and other stakeholders. We see most merit in additional data availability related to sustainability regulations/directives like NFRD, CSRD, the Taxonomy Regulation and the SFDR. Considering the urgent need for sustainable finance related data points, priority should be given to make ESG data available through ESAP above other data, in our view. We believe that providing ESG data through ESAP will further drive sustainable investing for all investors.
Read full responseResponse to Revision of Non-Financial Reporting Directive
13 Jul 2021
DUFAS strongly supports the development of a solid corporate sustainability reporting framework and sustainability standards. We believe that CSRD will improve the quality of sustainability information and increase the comparability of ESG data between investee companies. Moreover, we support the expansion of the scope to large undertakings as it will increase the coverage of sustainability data for investment portfolios. We also see merit in making sustainability information available in electronic format as this will spur the roll-out of a European Single Access Point (ESAP). Next to these general comments, we have remarks about six specific subjects and one observation (see attachment).
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