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European Sustainable Investment Forum

Eurosif

Eurosif is the leading pan-European association promoting Sustainable Finance at European level.

Lobbying Activity

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

16 Oct 2025 · SFDR and the Omnibus proposal

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

13 Oct 2025 · Sustainable finance

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

9 Oct 2025 · Sustainable finance disclosure regulation

Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné) and Third Generation Environmentalism Ltd and

14 Jul 2025 · Simplification, CSRD, CSDDD

Response to Revision of EU rules on sustainable finance disclosure

28 May 2025

The Sustainable Finance Disclosure Regulation (SFDR) review is a significant opportunity to scale-up finance for sustainable growth and the decarbonisation of the European economy, in line with the EUs strategic objectives. The implementation of SFDR significantly improved disclosures on, and consideration of sustainability risks and adverse sustainability impacts in investment decisions. However, some key challenges prevent the SFDR from fully delivering on its objectives: preventing greenwashing and helping channel capital towards industrial decarbonisation and sustainable growth. The framework must be reviewed building on its achievements, fixing aspects not working as intended to ensure it can fully deliver on these objectives. Please find Eurosifs high-level recommendations below. These will be presented in further detail in a report to be published in the coming weeks. Establish categories of products based on minimum criteria This review should create three categories of products, reflecting their main objectives: sustainable, transition, and binding environmental and/or social factors. They should be named following an EU-wide consumer survey to ensure they are meaningful to retail investors. Minimum criteria should include the establishment of a specific ESG/sustainability-related objective and the assessment of progress using credible indicators. It should also entail establishing minimum exclusions, building on those used in the ESMA guidelines on funds names, and adjusted to avoid carbon lock-ins. A horizontal impact lens across the categories, with dedicated criteria and disclosures should be established for products with impact objectives. Improve transparency for all financial products The SFDR review can help channel the savings of EU retail investors towards the real economy, leveraging on the increasing demand for sustainable products. This can be achieved through better comparability, by establishing minimum disclosures for all financial products on their sustainability risks and main adverse impacts on the environment or society. For categorised products, a limited list of relevant mandatory Principal Adverse Impact (PAI) indicators should be established. This information and the associated mitigation effort should be presented in a summarised, easy-to-understand way in dedicated consumer-facing disclosures. A disclaimer should clearly flag products that are not categorised under SFDR to retail investors. For these products, exposure to activities going beyond the revenue-based thresholds set in the exclusion list of the Paris-Aligned Benchmarks, should also be flagged in an additional disclaimer. Maintain meaningful entity-level disclosures Entity-level disclosures within SFDR should be maintained, preserve the disclosure of adverse impacts indicators across investors Assets under Management (AuM) and include an overview of their offer of financial products categorised under SFDR. Financial market participants should also explain their proprietary models and their methodologies to integrate sustainability risks. Finally, these disclosures should detail their due diligence policies to identify, monitor and address adverse impacts caused by their investee companies, including how sustainability-related engagement strategies are implemented accordingly. Reflect SFDR review changes in other regulations The SFDR review is an opportunity to adopt a holistic approach to EU rules that apply across the investment chain. This means preserving and streamlining the rules that would ensure access to essential corporate sustainability reporting data for investors, as part of the current negotiations on the Omnibus I simplification package. Reviewing SFDR would also entail adjusting rules on the distribution of products (MiFID/IDD), information to provide to retail investors (KID PRIIPS) and rules on benchmarks using ESG-related terms (BMR), to ensure they are consistent with the outcomes of the review.
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Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

1 Apr 2025 · Participation ina n Eurosif working group.

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

1 Apr 2025 · Exchange of views on the SFDR review

Meeting with Ilhan Kyuchyuk (Member of the European Parliament) and Institutional Investors Group on Climate Change

24 Mar 2025 · overview of positions on the Omnibus 1 package & sustainable finance

Meeting with Lara Wolters (Member of the European Parliament, Shadow rapporteur)

19 Mar 2025 · Omnibus (event)

Meeting with Ingeborg Ter Laak (Member of the European Parliament) and Institutional Investors Group on Climate Change and Principles for Responsible Investment

13 Mar 2025 · CSRD & CSDDD

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Institutional Investors Group on Climate Change and Principles for Responsible Investment

10 Mar 2025 · Exchange of views on the Omnibus package.

Meeting with Maria Luís Albuquerque (Commissioner) and

12 Feb 2025 · Sustainability Omnibus

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

11 Feb 2025 · Omnibus

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

13 Jan 2025 · Sustainable Finance

Meeting with Aurore Lalucq (Member of the European Parliament)

18 Dec 2024 · Omnibus, Sustainable Finance

Meeting with Radan Kanev (Member of the European Parliament)

18 Nov 2024 · Simplification Agenda

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Principles for Responsible Investment

4 Sept 2023 · Corporate Sustainability Due Diligence

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Principles for Responsible Investment

13 Jul 2023 · Sustainable finance

Response to European Sustainability Reporting Standards

7 Jul 2023

High-quality, comparable, and reliable corporate sustainability-related disclosures are a cornerstone of the EU sustainable finance framework. Please find attached Eurosifs detailed consultation response on the draft Delegated Act (DA) on the European Sustainability Reporting Standards (ESRS), which reflects the concerns and perspectives of the responsible investors community, committed to implement an ambitious sustainable finance framework in the EU. Investors and other financial market participants have been calling for improved availability of ESG data for years. However, Eurosif is deeply concerned by the latest changes introduced by the European Commission (EC) in this draft DA including the cross-cutting and sector-agnostic ESRS, which significantly reduce the ambition of the standards as compared to the technical advice of November 2022. EFRAGs final recommendations were a result of a lengthy and rigorous due process and represent a compromise across a wide range of European stakeholders within all relevant EFRAG bodies (Sustainability Reporting Board and Technical Expert Group). This includes representatives of companies (preparers), investors, other financial market participants and civil society. Following a public consultation during the summer last year, EFRAG proposals for this first set of standards were already reduced nearly by half, with the number of data points reduced by 47% as compared to the initial EFRAG proposals. Following strict due-process rules, EFRAG delivered a first set of standards which stroke the right balance in addressing the needs of different stakeholders and the objective of the corporate sustainability reporting which is to improve availability, quality, comparability and reliability of corporate ESG disclosures. The latest substantial modifications applied to these standards by the EC distort this carefully struck compromise, to the detriment of investors, the financial industry, and other stakeholders calling for improved sustainability disclosures. Following through on these changes would hinder the effectiveness of the Corporate Sustainability Reporting Directive (CSRD) as well as the implementation and coherence of the EU sustainable finance framework. Eurosif, jointly with PRI, IIGCC, EFAMA, UNEP FI and 93 investors and other financial market participants across Europe, call on the European Commission to review its draft Delegated Act. In particular, Eurosif deems crucial that the ESRS: -Consider as always material, the key environmental and social disclosures necessary to comply with the SFDR, the Benchmark Regulation and Climate Benchmark Delegated Acts, as well as Pillar 3 disclosure requirements; -Consider as always material, the key climate disclosure indicators and topics, including Scope 1, 2, and 3 GHG emissions, climate targets and transition plans; -Require explanations in case a sustainability topic is not deemed material. -Reconsider the voluntary nature of disclosures on biodiversity and own-workforce that would not be covered in the first point above, and require they are subject to materiality assessments. Eurosif also regrets that the disclosures on diversity policies regarding ethnicity, age, minority or vulnerable group, and educational and professional backgrounds, which are relevant from the social justice perspective and considered by an increasing number of investors, are not covered in the final first set of ESRS. This contradicts the objectives of the European Union reflected in existing legislation on equality in the workplace. Improved availability and quality of diversity-related disclosures is important for a just climate transition.
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Meeting with Pierre Karleskind (Member of the European Parliament) and EFRAG

27 Apr 2023 · Acte délégué - reporting extra-fiancier des entreprises

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders) and Finance Watch and

17 Jan 2023 · Corporate Sustainability Due Diligence

Meeting with Pascal Canfin (Member of the European Parliament)

1 Dec 2021 · Green finance

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

15 Nov 2021 · Sustainable finance

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

8 Apr 2021 · Sustainable finance