F2i SGR S.p.A.
Società di gestione del risparmio attraverso l'istituzione e la gestione di fondi di investimento alternativi riservati di tipo chiuso dedicati al settore delle infrastrutture
ID: 572520292370-58
Lobbying Activity
Response to Revision of EU rules on sustainable finance disclosure
30 May 2025
F2i SGR is Italy's largest independent infrastructure asset manager, with over 8 billion euros under management across sectors critical to the EU's sustainability agenda. Based on its operational experience in sustainable finance, F2i welcomes the opportunity to contribute to the review of the SFDR. F2i recognises that the SFDR has played a central role in enhancing transparency in sustainable finance. However, practical implementation has revealed several areas that might be improved with benefits on clarity, consistency, and operational feasibility. A key concern is the lack of a clear, operational definition of sustainable investment under Article 2(17). The current definition is overly broad and difficult to apply consistently across the market. F2i supports the introduction of more precise implementation methodology for structuring a proprietary sustainable investment framework, ensuring regulatory coherence across the market, improving investor confidence and preventing greenwashing. A second major issue is the current classification of financial products under Articles 8 and 9, which, although originally intended for disclosure purposes, has evolved into a de facto labelling system. This shift has generated legal uncertainty and interpretative divergence. F2i argues that greater precision in definitions and reporting obligations could reduce the need for a labelling regime on top and strengthen regulatory coherence. In case of adoption of a labelling system, F2i advocates for the formal recognition of a distinct category for transition finance that would enable the classification of products that support credible pathways toward sustainability. This would avoid penalising investments that, while not immediately sustainable, are essential to delivering the EU's environmental and social objectives. Flexibility, proportionate thresholds and coherence with existing frameworks such as the EU Taxonomy and CSRD will be key to implementation. More broadly, it is essential that the review of the SFDR does not take place in isolation but is considered in connection with the wider EU sustainable finance architecture. Any modification to corporate sustainability reporting requirements must be fully reflected in the obligations imposed on financial market participants under SFDR. Asset managers must not be expected to fill in data gaps resulting from reductions in corporate-level disclosures obligations. On financial products pre-contractual and periodic disclosure, F2i notes that the Regulatory Technical Standards templates are overly complex, rely heavily on open-ended responses, and include questions that might be useful clarify. This format undermines comparability across products and increases the reporting burden. F2i recommends introducing downloadable structured templates with numbered and closed-ended questions to improve comparability and consistency. F2i raises critical issues on PAI, either on PAI statement at entity level, suggesting PAI statement at fund level, or on specific calculation methodologies. In conclusion, F2i calls for targeted SFDR revisions that will: - integrate the most relevant clarifications from multiple Q&As and guidelines that have been published; - improve the clarity of definitions and reporting obligations; - introduce a coherent and practical approach to transition finance; - simplify and standardise disclosure templates and PAI indicators; - ensure full alignment with related EU legislation, including CSRD and EU Taxonomy. F2i remains committed to supporting EU institutions in developing a practical and credible regulatory framework that mobilises private capital toward a more sustainable and inclusive economy.
Read full responseMeeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)
4 Feb 2025 · Meeting to present the structure of the fund and its investment model
Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)
4 Feb 2025 · Sustainable finance