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Invesco Management SA

IMSA

Invesco Management SA is a Luxembourg-based investment firm providing global asset management services.

Lobbying Activity

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and BlackRock and

19 Sept 2025 · EU’s investment capacity in the context of SIU

Invesco supports tax-free rebalancing for new EU investment accounts

8 Jul 2025
Topic — European Commission initiative to develop a blueprint for cross-border retail investment products.
Message — The firm recommends that capital gains taxes only apply when money is withdrawn from the account. They also want these products to receive the most favorable national tax treatment available.12
Why — Tax-free portfolio adjustments would increase sales of Invesco's professional investment services.3
Impact — Commercial banks could see their deposit bases shrink as households shift savings.4
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and BlackRock and

2 Jun 2025 · Exchange with asset managers on the integration of EU capital market

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Fleishman-Hillard and

20 Feb 2025 · CMU discussion with asset management industry

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

20 Feb 2025 · Capital Markets Union (CMU) and Saving and Investment Union (SIU), with a focus on long-term savings accounts, the Non-Bank Financial Intermediation (NBFI) agenda, and the review of the UCITS Eligible Assets Directive.

Meeting with Gilles Boyer (Member of the European Parliament)

20 Feb 2025 · Simplification Omnibus

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

19 Feb 2025 · Exchange with Invesco and developments in asset management

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Fleishman-Hillard

19 Feb 2025 · Discussion on simplification.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and

19 Jun 2024 · Capital Markets Union

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

19 Jun 2024 · • Competitiveness/CMU • Financial stability • Retail investment • ESG/sustainability

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and BNP PARIBAS and

22 Feb 2024 · Retail investment Strategy

Meeting with Isabel Benjumea Benjumea (Member of the European Parliament, Rapporteur)

24 Apr 2023 · AIFMD

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BlackRock and

15 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Fleishman-Hillard and

26 Oct 2022 · Retail Strategy & Sustainable Investment

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and

26 Oct 2022 · EMEA Asset Management CEOs to discuss retail investor engagement as well as ESG/sustainable finance. Cab EVP Dombrovsksi also participated Andrea Beltramello.

Meeting with Esther De Lange (Member of the European Parliament) and BlackRock and Allianz SE

10 Oct 2022 · MiFIR/D - APA

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Kreab Worldwide

5 Sept 2022 · Capital markets, Sustainable finance and Digital finance

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

5 Sept 2022 · Topics: - Eu sustainable finance framework (including on the corporate sustainability reporting Directive) - CMU plan including on AIFMD review and on the consolidated tape.

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur) and BlackRock and

9 Mar 2022 · MiFIR Review and CMU Package

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Claude Bocqueraz (Cabinet of Commissioner Mairead Mcguinness) and

26 May 2021 · Retail investment

Response to Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

11 Sept 2020

Dear Madam, Sir, Please find attached Invesco’s response to the European Commission consultation on the draft Delegated Directive proposing to amend the MiFID II regime for research on small and mid-cap issuers and fixed-income instruments. Invesco welcomes the opportunity to contribute to the consultation, and thanks the European Commission for its constructive engagement with industry. Yours faithfully, Michael O’Shea Senior Public Policy Manager Invesco
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

31 Aug 2020

Invesco welcomes the opportunity to comment on the European Commission’s inception impact assessment on the proposed Delegated Regulation on Taxonomy-related disclosures by undertakings reporting non-financial information. Invesco has the privilege to just under $1.2 trillion of assets on behalf of our clients (as at August 2020). Our investment teams and clients increasingly view sustainability issues as important factors in driving long-term value of the companies we invest in. Accessing high quality data on such issues is, therefore, of the highest importance. We see the potential for the Taxonomy to become a highly valuable investment tool to be able to identify companies that make a significant contribution to the EU’s environmental objectives. In particular, the Taxonomy represents an innovation in that it enables investors to translate carbon emissions into financial metrics. Some of our investment teams have already begun assessing their holdings against the TEG’s advice and entering into dialogue with the management of the companies in which they invest to have a better understanding of how these companies are responding to the Taxonomy. However, the lack of reliable data represents a major impediment to integrating the Taxonomy into our investment decision making in a more systematic way. We, therefore, view this Delegated Regulation, which will set the information that investee companies should report on with regards to the Taxonomy, as vital to this endeavour. We believe that the following three issues will be critical for investors to embrace the Taxonomy: o A defined methodology for companies to calculate their turnover, CapEx and Opex to ensure reliability, comparability and, ultimately, auditability of the data; o Sufficient granularity of the information reported to align with investor preferences and needs; o Encouraging firms to report not only on those activities that are fully aligned to the Taxonomy but also activities that are potentially aligned and any forward-looking targets to so that investors can understand the direction of travel; o Reporting not only on the numbers but also the more qualitative elements, including the companies’ due diligence policies with regards to Do No Significant Harm and minimum social safeguards. Please see the attached note for further details on each of these.
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Response to Action Plan on the Capital Markets Union

4 Aug 2020

Dear Madam, Sir, Please find attached Invesco’s response to the European Commission’s request for feedback on A Capital Markets Union for People and Businesses – New Action Plan Roadmap. Invesco welcomes the opportunity to respond to this request for feedback, and thanks the European Commission for its constructive engagement with all stakeholders. We look forward to continuing the discussion as further details of the new Capital Markets Union Action Plan are announced. Kind regards, Michael O’Shea Invesco Senior Public Policy Manager Direct: +44 (0) 207 034 3819 Mobile: +44 (0) 7597 119 233 Email: michael.oshea@invesco.com
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

The overarching objectives set out in the European Commission’s Sustainable Finance Action Plan is to re-orient capital flows towards a more sustainable economy and to mainstream sustainability. The ambition being to incentivise financial market participants to offer sustainable investing options to clients that meet client preferences, recognising that client preferences and objectives are not only financial but can also be non-financial. By encouraging investors to channel their savings into sustainable products, the aim is to ecnourage the flow of capital to financing Europe’s sustainability objectives, including the just transition. At Invesco, we have seen the growing appetite for ESG investing approaches and have been partnering with our clients to develop ESG strategies for over 20 years. In our experience, client needs and expectations in relation to sustainable investing vary greatly- for some, they are seeking to align their investments with their values by excluding certain activities from their portfolios; for others, their approach is built around the “theory of change” and that they can use their investments to incentivise companies to change their business practices to become more sustainable; for others still, they want to commit capital to finance projects that are already sustainable. We believe that it is only by fostering and catering to these diverse needs that we can fulfil the ambitions of the Sustainable Finance Action Plan to mainstream sustainability. Suitability and product governance are the cornerstone of investor protection under MiFID. The overarching objective of suitability is to ensure that advisers understand the risk profile and investment objectives of the client to ensure that the advice given “meets the preferences, needs and other characteristics of the retail client”. Since suitability applies to all clients, from retail all the way to the largest institutional clients, the framework needs to be flexible and proportionate to ensure that advisers can assess suitability in a way that is meaningful for the end client. The product governance rules, equally, aim to ensure that both product manufacturers and distributors consider the needs and objectives of clients to ensure that clients are offered appropriate products. The ultimate aim of the rules is to ensure that clients are offered products and investments that fit with their risk profile and investment objectives. Under the existing MiFID framework, both risk and investment objective are broadly defined, reflecting the breadth of different objectives investors may have, as well as different attitudes to risk. As set out above, investor needs and preferences when it comes to sustainability are equally diverse. We therefore believe that this breadth of needs and preferences shoud to be taken into account in the suitability framework. We would therefore encourage the European Commission to define „sustainability preferences“ as a broad concept relating to the many ways in which clients may wish to have sustainability factors reflected in their investments rather than a narrow concept for a niche set of products. We believe that the suitability and product governance framework presents an opportunity to place client needs at the heart of the sustainable finance agenda, with the focus on enabling rather than restricting choice. To achieve this, the definition of “sustainability preferences” should remain broadly defined to cater to the wide range of investor needs and approaches. However, more detailed guidance on the application of “sustainability preferences” as part of the product governance and suitability guidelines based on in-depth consumer testing of client needs and objectives with regards to sustainability preferences, could help guide investors to products and strategies that align with their preferences.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

The overarching objectives set out in the European Commission’s Sustainable Finance Action Plan is to re-orient capital flows towards a more sustainable economy and to mainstream sustainability. The ambition being to incentivise financial market participants to offer sustainable investing options to clients that meet client preferences, recognising that client preferences and objectives are not only financial but can also be non-financial. By encouraging investors to channel their savings into sustainable products, the aim is to ecnourage the flow of capital to financing Europe’s sustainability objectives, including the just transition. At Invesco, we have seen the growing appetite for ESG investing approaches and have been partnering with our clients to develop ESG strategies for over 20 years. In our experience, client needs and expectations in relation to sustainable investing vary greatly- for some, they are seeking to align their investments with their values by excluding certain activities from their portfolios; for others, their approach is built around the “theory of change” and that they can use their investments to incentivise companies to change their business practices to become more sustainable; for others still, they want to commit capital to finance projects that are already sustainable. We believe that it is only by fostering and catering to these diverse needs that we can fulfil the ambitions of the Sustainable Finance Action Plan to mainstream sustainability. Suitability and product governance are the cornerstone of investor protection under MiFID. The overarching objective of suitability is to ensure that advisers understand the risk profile and investment objectives of the client to ensure that the advice given “meets the preferences, needs and other characteristics of the retail client”. Since suitability applies to all clients, from retail all the way to the largest institutional clients, the framework needs to be flexible and proportionate to ensure that advisers can assess suitability in a way that is meaningful for the end client. The product governance rules, equally, aim to ensure that both product manufacturers and distributors consider the needs and objectives of clients to ensure that clients are offered appropriate products. The ultimate aim of the rules is to ensure that clients are offered products and investments that fit with their risk profile and investment objectives. Under the existing MiFID framework, both risk and investment objective are broadly defined, reflecting the breadth of different objectives investors may have, as well as different attitudes to risk. As set out above, investor needs and preferences when it comes to sustainability are equally diverse. We therefore believe that this breadth of needs and preferences shoud to be taken into account in the suitability framework. We would therefore encourage the European Commission to define „sustainability preferences“ as a broad concept relating to the many ways in which clients may wish to have sustainability factors reflected in their investments rather than a narrow concept for a niche set of products. We believe that the suitability and product governance framework presents an opportunity to place client needs at the heart of the sustainable finance agenda, with the focus on enabling rather than restricting choice. To achieve this, the definition of “sustainability preferences” should remain broadly defined to cater to the wide range of investor needs and approaches. However, more detailed guidance on the application of “sustainability preferences” as part of the product governance and suitability guidelines.
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Response to Integration of sustainability risks and factors related to alternative investment fund managers

6 Jul 2020

Invesco is committed to the integration of financially material ESG factors (hereafter referred to as sustainability risks integration) into its investment decision-making, a journey we have been on as a business for over 20 years. Views on what constitutes a financially material ESG factor and ESG integration as a practice have evolved considerably over the past years and continue to evolve at pace due to increasingly sophisticated expectations of our clients and better access to high quality ESG data. It is our core belief that to be meaningful, the integration of sustainability risks must be embedded in the investment philosophy of the investment team, taking into account asset class and investment style, but also the objectives and investment strategy of the fund. Therefore, there is no one-size-fits-all approach to taking sustainability risks into account. We therefore welcome that the European Commission’s draft Delegated Acts propose a high-level principles-based approach that will allow for firms to develop best practice and continue to innovate in this space, driving higher standards over time. Taken together with the new Sustainable Disclosure Rules, we expect the new framework to create a “race to the top” for market leading ESG integration. At its heart, the integration of sustainability risks is about delivering better financial outcomes for our clients while respecting their objectives and investment needs. While financial market participants may be mandated under the Sustainable Finance Disclosures Regulation to consider principal adverse impact, it would contravene the duty of care that we have towards our clients to act in a way that is not in line with their investment needs and beliefs. This is why we have suggested changes in the attached submission to the language around the inclusion of principal adverse impact to ensure the primacy of the principal-agent relationship and the duty of care we have towards our clients to invest at all times in keeping with their needs and objectives. We also make some other drafting suggestions that maintain the spirit of the European Commission’s proposals but would make the requirements for firms clearer.
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

6 Jul 2020

Invesco is committed to the integration of financially material ESG factors (hereafter referred to as sustainability risks integration) into its investment decision-making, a journey we have been on as a business for over 20 years. Views on what constitutes a financially material ESG factor and ESG integration as a practice have evolved considerably over the past years and continue to evolve at pace due to increasingly sophisticated expectations of our clients and better access to high quality ESG data. It is our core belief that to be meaningful, the integration of sustainability risks must be embedded in the investment philosophy of the investment team, taking into account asset class and investment style, but also the objectives and investment strategy of the fund. Therefore, there is no one-size-fits-all approach to taking sustainability risks into account. We therefore welcome that the European Commission’s draft Delegated Acts propose a high-level principles-based approach that will allow for firms to develop best practice and continue to innovate in this space, driving higher standards over time. Taken together with the new Sustainable Disclosure Rules, we expect the new framework to create a “race to the top” for market leading ESG integration. At its heart, the integration of sustainability risks is about delivering better financial outcomes for our clients while respecting their objectives and investment needs. However, while financial market participants may be mandated under the Sustainable Finance Disclosures Regulation to consider principal adverse impact, it would contravene the duty of care that we have towards our clients to act in a way that is not in line to their investment needs and beliefs. This is why we have suggested changes in the attached document to the language around the inclusion of principal adverse impact to ensure the primacy of the principal-agent relationship and the duty of care we have towards our clients to invest at all times in keeping with their needs and objectives. We also make some other drafting suggestions that maintain the spirit of the European Commission’s proposals but would make the requirements for firms clearer, which can be found in the attached submission.
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Response to Climate change mitigation and adaptation taxonomy

21 Apr 2020

We appreciate the in-depth and rigorous work that the Technical Expert Group has undertaken over the last 20 months to develop the technical screening criteria for climate change mitigation and adaption under the Taxonomy Regulation. In particular, we recognise that efforts have been made to address some of the issues we had previously identified with their earlier advice, namely in relation to usability of the Taxonomy. As a global asset manager, we recognise the potential in applying the Taxonomy to our investments and some of our portfolio managers are already exploring how to integrate the Taxonomy into their investments. However, we believe that several improvements to the TEG proposals would make the Taxonomy more readily operational both for companies and investors alike and would allow for the Taxonomy to have greater applicability for global investments. Our detailed suggestions can be found in the attached comment paper but broadly cover: - Scope and cross-cutting issues - Alternative pathway to transition - Maximising use of existing standards to limit administrative burdens and complexity - Consistency with EU Green Deal - International applicability
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

11 Feb 2019 · Sustainable Finance

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

4 Dec 2018 · Sustainable Finance

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen), Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen) and

25 Mar 2015 · Investment plan and EU economic outlook