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Institutional Investors Group on Climate Change

IIGCC

IIGCC is a global investor network working toward a net-zero and climate-resilient economy.

Lobbying Activity

Meeting with Stefan Leiner (Head of Unit Environment)

19 Nov 2025 · Exchange of views about Industrial and Livestock Rearing Directive (IED) and investor views

Meeting with Dan Dionisie (Head of Unit Justice and Consumers)

28 Oct 2025 · EU Stewardship and update of the Shareholder Rights Directive

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

28 Oct 2025 · Sustainable Finance Policy

Meeting with Kurt Vandenberghe (Director-General Climate Action)

27 Oct 2025 · Update from financial sectors investment companies

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

27 Oct 2025 · SFDR revision

Meeting with Astrid Dentler (Cabinet of Commissioner Wopke Hoekstra)

27 Oct 2025 · Sustainable finance; transition finance

IIGCC Calls for Simplified Sustainable Finance and Transition Categories

30 May 2025
Topic — Review of EU rules on sustainable finance disclosure to prevent greenwashing.
Message — The group requests simplified entity-level disclosures and clearer definitions for sustainable investments. They propose introducing dedicated product categories including a specific focus on transitioning assets. For real estate, they advocate for harmonized energy ratings and mandatory tenant data-sharing.123
Why — This approach would reduce administrative burdens and clarify rules for environmental transition strategies.45
Impact — Tenants would face new legal obligations to share energy data with landlords.6
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Meeting with Ilhan Kyuchyuk (Member of the European Parliament) and European Sustainable Investment Forum

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

Meeting with Ingeborg Ter Laak (Member of the European Parliament) and Principles for Responsible Investment and European Sustainable Investment Forum

13 Mar 2025 · CSRD & CSDDD

Meeting with Lena Schilling (Member of the European Parliament)

12 Mar 2025 · Omnibus Package

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Principles for Responsible Investment and European Sustainable Investment Forum

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

Meeting with Sigrid Friis (Member of the European Parliament)

19 Feb 2025 · Omnibus

Meeting with Maria Luís Albuquerque (Commissioner), Maria Luís Albuquerque (Commissioner) and

29 Jan 2025 · SIU and the usability of the sustainable finance framework

Meeting with Alexandr Hobza (Cabinet of Executive Vice-President Stéphane Séjourné)

29 Jan 2025 · The IIGCC introduced their organisation and presented the investors’ perspective on the decarbonisation of the EU industry and the links to competitiveness.

Meeting with Pierre Schellekens (Director Energy) and

29 Jan 2025 · Exchange of upcoming initiatives of EC to attract private investments, notably by establishing a common language between policymakers and investors, to facilitate investments in energy generation, infrastructure and energy efficiency.

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

28 Jan 2025 · EU's future sustainable finance framework

Meeting with Wopke Hoekstra (Commissioner) and

28 Jan 2025 · Exchange of views on sustainable financing in Europe

Meeting with Lara Wolters (Member of the European Parliament)

16 Oct 2024 · Corporate Sustainability

Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

This feedback was developed in collaboration with a number of IIGCC members but does not necessarily represent the views of the entire membership, either individually or collectively. Priorities: Permitting. Accelerated permitting both for new renewable energy construction and for grid infrastructure. We endorse the Renewable Energy Directive's move to consider renewable energy deployment as an 'overriding public interest'. Directing national authorities to take no longer than two years to approve renewable projects is also a positive move in our view. It is essential that member states transpose the directive into legislation in a swift and comprehensive manner. Grid connection queues. Projects should be prioritised for approval based on how advanced the project is and whether the project is of strategic importance. This should help to de-prioritise more speculative applications. Auction design. Auction designs must favour sustainable models with viable business case. The last couple of years have demonstrated how important inflation adjustment mechanisms will be to the long-term viability of projects. We see the move away from negative bidding in some countries as a positive development. The excessive upfront costs associated with negative bidding ultimately make electricity more expensive for consumers, add unnecessary financial risk that end up squeezing the supply chain and hindering project economics while unintentionally delaying the energy transition. Instead of revenue derived through auctions, introduce a revenue sharing mechanism that links seabed lease payments or fees directly to the revenue derived from projects to promote both project profitability and the utilization of seabed. Reward sustainable innovation in auctions to drive value through industrialization, such as system integration, rather than fuelling a race to ever larger turbines that hinders bankability, drives uncertainty in the supply chain and limits the ability to reinvest into scaling for accelerated build out. We believe that due to the time value of carbon, removing a ton of CO2 today is worth more than a ton CO2 tomorrow, so we should seek to achieve that with the fastest possible rollout of renewable energy like wind. In order to achieve that, the industry requires stable, viable and profitable supply chains that rely on standardized industrial manufacturing. The best way to get there is incentivize fast, standardized rollout via auction design, rather than seek the invention of ever larger turbines. Use adequate prequalification requirements to incentivize project realization, secure high project quality, stave off speculative bidding and to level the playing field across bid submissions. Remove the speculative element of bids in auctions by introducing a requirement that all assumptions are supported by a binding technology commitment that includes a certification plan. Auction systems that are not driven on price can introduce non-price criteria strategically, to bring value to projects. Carefully select those criteria which are harmonized (internationally or regionally), transparent, measurable, and which are verifiable without resulting in inflating costs, additional bureaucracy, and delays in project development. All meetings, communications and initiatives undertaken by IIGCC are designed solely to support investors in understanding risks and opportunities associated with climate change and take action to address them. Our work is conducted in accordance with all the relevant laws, including data protection, competition laws and acting in concert rules. IIGCCs services to members do not include financial, legal or investment advice.
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Meeting with Dino Toljan (Cabinet of Vice-President Maroš Šefčovič)

23 Jan 2024 · Support on 2030 target

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

18 Dec 2023

Disclosure remains the foundation of the EUs Sustainable Finance Action Plan, and the ESRS are an essential component of this. They establish the parameters for the detailed, credible and comparable reporting needed by investors to assess their exposures to climate-related risks and opportunities, inform stewardship activities and investment decisions, and reorient capital in line with a net zero world. However, we were disappointed by the Commissions decision to move away from mandatory disclosure requirements under the sector-agnostic standards, with all reporting topics now subject to materiality assessment. In this uncertain context, and noting the EUs wider work in taking forward comprehensive policies for sectoral decarbonisation under the Fit for 55 package, the need for sector-specific disclosures has become more urgent than ever. Many of IIGCCs members have committed to net zero and are seeking to assess the alignment of their holdings with a 1.5c world. Increasingly, this requires a deeper understanding of the transition challenges and opportunities within key sectors, and of how companies are planning to navigate them. Investors rely upon company disclosures to make these assessments. At IIGCC, and along with CA100+ network partners, we have been working to establish investor expectations for sector-neutral and sector-specific disclosures that provide investors with the information they need to interpret how well-positioned an entity is for the transition. Enhanced regulatory disclosures would serve the same aim, by improving the baseline of reporting across the board. We note that it would have been highly challenging, if not impossible, for EFRAG to deliver 40 sector standards by June 2024, as was originally set out in the Corporate Sustainability Reporting Directive. Nevertheless, significant progress has been made in drafting and developing sector standards for a number of high impact sectors (e.g. Mining, Quarrying and Coal; Oil and Gas; Road Transport). Given that a number of these standards are near-final, our view is that they could be adopted as soon as practicable, and well before the new 2026 implementation date. IIGCC would also like to highlight the need for closer and more transparent collaboration with investors, who arguably represent the key audience for corporate disclosures. This would not only help to ensure the standards are decision-useful for users of sustainability disclosures, but also help to relieve the burdens that have been placed on individuals and organisations that have contributed to the drafting of standards to date. We have developed a range of sector-specific and investor-led standards, and have sought to feed into and support the development of EFRAGs sector-specific standards, including by applying to relevant sector-specific communities. However, we have found the process opaque and challenging to navigate, and have received little to no communication on the status of our application or on opportunities to participate in discussions. The development of standards requires the input of a diverse set of users and preparers of disclosures, to ensure that they will be robust and widely useful. Based on the above, our key recommendations to the Commission are as follows: 1. Adopt the first set of five high impact standards, many of which are far-advanced, at the earliest possible opportunity. This will provide investors and other users of corporate sustainability disclosures with the granular indicators and information they need to assess the transition potential of their holdings more credibly, and better support their engagement efforts. 2. Prioritise the development and adoption of standards for the remaining high-impact sectors identified by EFRAG. 3. Increased communication and engagement with key external stakeholders (including investors), including clarity on avenues to feed into the development and design of sector-specific standards.
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

25 Jul 2023 · CLG Europe 2040 response

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Climate Strategy

6 Jul 2023 · The Energy Performance of Buildings Directive

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

1 Mar 2023 · Staff level: CSDD Directive

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

1 Mar 2023 · Meeting to discuss the position paper of the Institutional Investors Group on Climate Change (IIGCC

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

25 Jan 2021 · Dialogue with investors on Green deal

Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

To support the alignment of Europe’s economy with net zero emissions, the Institutional Investors Group on Climate Change (IIGCC) recommends the draft Delegated Regulation under the Taxonomy Regulation upholds, as a minimum, the level of climate ambition and associated criteria recommended by the Technical expert group on sustainable finance (TEG). With regards to fossil fuels, IIGCC’s engagement with corporates is seeking to encourage a shift in business model away from fossil fuels, and towards scaled up investments in renewables and other zero emission technologies. In particular, we would discourage any changes to the current climate change mitigation criteria for electricity generation within the draft Delegated Regulation (100g CO2/kWh) which would see natural gas without abatement (e.g. without carbon capture) entering the scope of the sustainable taxonomy. For example, with respect to section 4.7 of Annex 1, if natural gas without abatement (e.g. without carbon capture) was to become consistent with the taxonomy, this would mean many energy companies would presently demonstrate alignment with the taxonomy, and without enacting climate transition plans in line with achieving economy-wide net zero emissions by 2050. This would frustrate the efforts of investors seeking to drive the decarbonisation of emissions intensive sectors, and would be inconsistent with the recommendations of the TEG. IIGCC has more than 270 members, mainly pension funds and asset managers, across 16 countries and representing over €35 trillion in assets under management. Our mission is to mobilise capital for the net zero transition and to ensure resilience to the impacts of a changing climate by collaborating with business, policy makers and fellow investors. As the leading investor group on climate change in Europe, the IIGCC strongly supports the European Green Deal’s objective of making Europe’s economy climate neutral by 2050.
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

11 Dec 2020 · Green deal - Paris Agreement

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

7 Dec 2020 · EU taxonomy framework

Response to Carbon Border Adjustment Mechanism

24 Mar 2020

On behalf of the Institutional Investors Group on Climate Change (IIGCC) - see www.iigcc.org IIGCC's investor members strongly support carbon pricing as a means of sending clear, long-term investment signals to support the transition to a net zero emissions economy. IIGCC has consistently supported greater climate ambition in the EU ETS through its different Phases and reforms. We are now working with our members on a more detailed consideration of the potential carbon border adjustment mechanism. At a high level, there is consensus on the following principles: • If such an approach were to be proposed, IIGCC would strongly support the Commission's intention that it replace, rather than supplement, the current free allocation and compensation provisions in the ETS Directive. This would rightly prevent any "double compensation" to EU operators. • IIGCC also supports full compatibility with WTO rules in order to make such a mechanism workable. This is important from a technical, legal and political perspective. • Linked to this, IIGCC would expect EU policymakers to ensure that any wider implications of the carbon border adjustment mechanism did not result in impacts that could jeopardise the overall environmental integrity of the carbon market. In particular, due consideration should be given to the impact of such an approach on the EU’s international relations, its on-going climate diplomacy work, and its global climate leadership. • Finally, any carbon border adjustment mechanism must be implemented in a smooth and efficient manner to avoid any shocks to the EU carbon market, while ensuring continued emissions reductions.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

10 Dec 2019 · Clean energy transition and sustainable investment

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Nathalie De Basaldua Lemarchand (Cabinet of Vice-President Jyrki Katainen)

1 Oct 2019 · Sustainable Finance

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

1 Oct 2019 · Discussion on the future of EU transport policy and the role of investors in mobilising private capital towards a decarbonisation strategy and particularly on how sustainable finance can be channelled into new technologies and infrastructure, particularly in light of the need to ensure a low-carbon transition across all industries.

Response to Institutional investors' and asset managers' duties regarding sustainability

21 Aug 2018

See attached document for full policy position. In summary, in its core recommendations IIGCC urges the EU to: 1. Set out a clear, long-term policy framework for the real economy – encompassing energy, transport and industry – backed up by concrete targets and objectives, as a priority issue, to move capital to support a transition to a sustainable low carbon economy. 2. Work towards determining a definition of fiduciary duty that encompasses all financially material sustainability issues. 3. Adopt a global leadership position in implementation of the TCFD recommendations, initially through fostering and sharing best practice at national level to allow for the future development of possible guidance or legislation. 4. Consider, in consultation with the financial community, the merits of developing a standardised disclosure template for green bonds to support the provision of more relevant, reliable, and comparable information. 5. Develop guidance on how different types of investment are compatible (or not) with long-term EU policy targets. 6. Pursue opportunities to encourage more research on sustainability issues and on the alignment of fund manager incentives towards the longer term. 7. Continue work to develop a classification system for sustainable assets and financial products. 8. Encourage Credit Ratings Agencies to incorporate sustainability and long-term risks into their ratings frameworks. 9. Reflect on how it could help to bridge the current gap that exists within the European financial system – whereby expertise and activities are concentrated in a handful of countries – through the provision of information on best practice, resources, and training. 10. Ensure that all work undertaken to establish new EU norms, rules or practices builds upon existing best practice, takes into account global perspectives, and is pursued in consultation with established experts.
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Meeting with Miguel Arias Cañete (Commissioner)

1 Mar 2016 · policy framework for investment in climate-friendly technologies

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Fleishman-Hillard

1 Mar 2016 · Climate Change and investments

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

1 Mar 2016 · Climate Change

Meeting with Maroš Šefčovič (Vice-President) and

30 Oct 2015 · creation of a network of Energy Union Business Ambassadors

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

20 Jan 2015 · Climate change

Meeting with Maroš Šefčovič (Vice-President)

20 Jan 2015 · Energy Union and investments, notably energy efficiency