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The Investment Association

IA

The Investment Association represents UK investment managers operating across Europe, managing €10.6 trillion globally and advocating for better investment outcomes for clients, companies and the economy.

Lobbying Activity

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque), Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

24 Sept 2025 · Developments in capital markets and asset management

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

23 Sept 2025 · Asset management (SIU, SFDR)

Response to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector

21 Jul 2025

Auto-Enrolment in Pension Schemes The Investment Association (IA) welcomes the European Commissions Call for Evidence on Supplementary Pensions and supports the Savings and Investments Unions goals to develop high-quality supplementary pensions that can help people in retirement. The importance of Automatic Enrolment In particular, based on our experience in the UK, we are strong supporters of Automatic Enrolment (AE) into workplace pensions, where the evidence has shown that it can have a significant impact on participation rates in workplace pensions. By making the focus of AE workplace provision, this helps to maximise the covered population, while also keeping the costs of provision lower relative to the cost of acquiring individual retail customers. Since phasing in AE over the period 2012 - 2018, pension membership in the UK among private-sector employees has increased to nearly nine in ten eligible workers , with membership of occupational Defined Contribution (DC) schemes rising from 2.1 million in 2011 to 21 million in 2019. This clearly shows that the impact of AE on pension coverage is extremely powerful. The design of Automatic Enrolment It is critical to get the design and implementation of AE right. Again, based on our experience in the UK, we recommend the following key features: Phased implementation, starting with larger employers and progressing to smaller ones, along with gradual contribution increases to reach the minimum level. In the UK this resulted in a six-year implementation period, easing some of the compliance challenges for employers, particularly smaller ones that were responsible for arranging pensions for their employees for the first time. Minimum contribution levels, with pre-agreed future increases to achieve a level of contributions sufficient to ensure adequate retirement outcomes. In the UK, the 8% minimum has come to be viewed as a Government-sanctioned appropriate amount, whereas in reality it was only ever intended to replace around 45% of median earnings. While there is widespread recognition in the UK of the need for higher contributions, the politics of further increases to the AE minimum have proven challenging to overcome, particularly in the context of a prolonged period of weak economic growth. The result is that, for all the success of AE in boosting coverage, millions of UK citizens are likely still under-saving for their retirement. In contrast, in the Australian Superannuation pension system, contributions started at 3% at the programs outset in 1992 but have increased incrementally over time to reach 12% today. The use of default investment strategies to provide pension savers with access to professionally-managed, well-diversified investment strategies. There is evidence around the world to suggest that people do better in default investment strategies, in comparison to making their own investment decisions . The design of these strategies should be left to pension providers and their appointed investment managers operating within the framework of the Prudent Person Principle. However, the overarching investment strategy should take account of the principles of life-cycle investment, whereby individuals far from retirement can take appropriate levels of risk, owing to their time horizon and ability to make pension contributions far into the future. The level of risk can be reduced as individuals get closer to retirement, albeit the level of de-risking will need to be compatible with the way that people choose to access their DC pensions in retirement. For example, for those remaining invested through retirement and taking an income from their portfolio, there will be a continued need to take some risk in retirement. Attractive tax incentives to encourage people to save for their retirement. Implementing Automatic Enrolment with these features in place should help EU countries put in place a solid foundation for improving their citizens retiremen
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Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Jun 2025 · Savings and Investments Union

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and Swiss Finance Council and

6 Jun 2025 · Sustainability Omnibus

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

The Investment Association represents 250 investment managers, a third of whom are headquartered in the EU, and who collectively operate from 642 offices across the EU. Our members put 10.6 trillion to work in the global economy, representing 37% of the 28.6 trillion in assets managed in Europe. They manage 2.5 trillion for European savers and invested 843 billion into EU businesses and projects last year while providing access to global investment opportunities. The IAs members, as both significant investors in EU markets and managers of the investments of a large number of EU-based savers, welcome the opportunity to respond to the European Commissions Call for Evidence on EU market integration and efficient supervision. This Call for Evidence follows the recent publication of the Commissions Targeted Consultation on the integration of EU capital markets. The IA is a member of the European Fund and Asset Management Association (EFAMA), and has provided input into their response to the targeted consultation. As such, we support their response to that consultation, which we see as representing the views of the IA as well as the wider European asset management industry. In our attached response to this Call for Evidence, we specifically highlight a number of areas which were highlighted by IA members during the consultation process as being of particular importance. We thank the Commission for their engagement with the industry, and would welcome further discussion on any of the topics we raise above.
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Investment Association urges EU to align sustainability rules with UK

29 May 2025
Topic — The European Commission is revising sustainable finance rules to simplify disclosures and greenwashing.
Message — The association calls for product categories that align with international frameworks like the UK regime. They request removing mandatory entity-level reporting and excluding private investment mandates from the regulation's scope.123
Why — A harmonized approach would minimize regulatory fragmentation and lower administrative costs for asset managers.4
Impact — Customers may face limited options and higher costs if regulatory divergence persists between jurisdictions.5
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Mar 2025 · Discussion on barriers and how to grow capital markets

The Investment Association Urges Simpler EU Securitisation Rules

25 Mar 2025
Topic — This initiative reviews the functioning of the EU securitisation framework's prudential rules.
Message — The IA requests a principles-based approach to allow tailored risk assessments. They advocate for streamlining disclosure templates to reduce regulatory burdens. Members want simplified standards to encourage more investment in SME securitisations.123
Why — These measures would significantly reduce compliance costs and administrative complexity for firms.45
Impact — Supervisory authorities may face reduced visibility if standardized disclosure templates are simplified.6
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Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

19 Mar 2025 · Exchange of views on financial services policy developments in the EU and the UK

Meeting with Fernando Navarrete Rojas (Member of the European Parliament)

19 Mar 2025 · European Savings and Investments Union

Response to Savings and Investments Union

5 Mar 2025

Europe can only meet its future financing needs by empowering individuals to invest, with a well-functioning, efficient, and integrated capital market essential to Europes long-term economic growth. The Savings and Investment Union (SIU) is a key opportunity to increase retail participation in European markets and support these broader economic objectives. The UKs Individual Savings Account (ISA) tax wrapper has fostered a long-term saving and investment culture and is a compelling model to draw from when considering tax-efficient, simple, and accessible products in the EU. Specifically, we explore how key features of ISAs could inform the development of best practices for incentivising the uptake of tax-advantaged accounts. Mobilising Savings More Effectively - An Accessible Investment Framework The ISA is a tax-advantaged savings and investment vehicle for UK residents, designed to encourage long-term saving and investment. Since 1999, these have allowed individuals to save and invest without incurring income or capital gains tax on: Cash ISAs traditional savings accounts but with tax-free interest; Stocks and Shares ISAs to invest in equities, bonds, and funds with tax-free growth; Lifetime ISAs (LISAs), aimed at first-time homebuyers and retirement savings; and Innovative Finance ISAs, which facilitate investments in peer-to-peer lending and crowdfunding platforms. Parents can open junior cash and stocks and shares ISAs for their children. ISAs offer a structured way to grow wealth, with an annual contribution limit of £20,000 (£9,000 for junior ISAs). Investors can choose from various asset classes, including funds, stocks, bonds, and cash, to align with their financial goals. Cash ISAs suit short-term savings or emergency funds, while Stocks and Shares ISAs offer growth and inflation protection. Even small, regular investments can add up over time. They can be self-directed or advisor-managed, promoting financial inclusion while enabling access to diverse global investment opportunities, helping to maximise returns. Tax-Advantaged Savings One of the advantages of ISAs is the tax incentives they offer, which help drive capital from low-yield deposits into investment. The absence of income tax and capital gains tax on ISAs has made them an attractive long-term savings vehicle. As a result: ISAs have accumulated £700 billion in investments since inception. In the 2022/23 tax year, 12.4 million ISA accounts were subscribed to, an increase of 1.4 million from 2021/22. In 2022/2023, a third of ISA subscriptions were to Stocks and Shares ISAs. Facilitating broader financial well-being The UKs Lifetime ISA (LISA) is an example of how savings instruments can be designed to achieve dual objectiveshelping save for homeownership or retirement while incentivising these savings through a 25% government bonus. Savers aged 18 to 39 can contribute up to £4,000 annually, receiving a maximum bonus of £1,000 annually. Market research by the IA in March 2024 found that 46% of surveyed retail investors saved for retirement, expecting better long-term returns than cash deposits. The funds can be used for a first home (up to £450,000) or withdrawn tax-free after age 60 for retirement. Early withdrawals incur a 25% penalty, losing the government bonus and reducing savings by 6.25%. The LISA effectively aligns personal savings with goals of homeownership and retirement. Building on the ISA Experience Recommendations for the EU To address the EUs high proportion of savings in low-yield deposits, best practices could be promoted for developing tax-advantaged investment savings accounts at national level. These could be informed by successful models like the ISA in order to achieve a range of complementary objectives: Support diverse long-term investments across public and private markets, including green finance and start-ups. Incentivize savings for homeownership and retirement to build financial res
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

21 Jan 2025 · Exchange of views on capital markets

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

21 Oct 2024 · T+1 settlements

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

1 Oct 2024 · Capital Markets Union

Investment Association urges EU to simplify cross-border tax relief

18 Sept 2023
Topic — A proposal to standardize and speed up withholding tax relief procedures across Europe.
Message — The group recommends removing exclusions for pension funds and shortening refund processing times. They also seek recognition for non-EU tax residency documents.123
Why — Faster relief would improve liquidity and reduce the financial burden of managing international investments.45
Impact — Pensioners and individual savers could suffer from reduced investment returns and higher costs.6
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

13 Jun 2023 · Retail investment strategy

Response to EMIR Targeted review

21 Mar 2023

Good afternoon, Please find attached the Investment Association's comments on the EMIR 3.0 proposals. The IA welcomes the opportunity to provide feedback and would be happy to discuss further any of the items we raise in our response.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

26 Jan 2023 · Retail investment strategy, CMU action plan

Investment Association seeks DEBRA tax exemptions for fund subsidiaries

29 Jul 2022
Topic — EU proposal to encourage equity financing over debt through new tax allowance rules.
Message — The group requests that the definition of financial firms be updated to exclude fund subsidiaries. They want these entities carved out to maintain consistency with other European tax directives.12
Why — Excluding these subsidiaries would protect the tax-free nature of fund structures and prevent new costs.34
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Response to Central securities depositories – review of EU rules

26 May 2022

The Investment Association (IA) welcomes the opportunity to feed back on the proposed changes to the Central Securities Depositories Regulation (CSDR) and in particular, the European Commission’s aim to make the settlement discipline regime more effective and proportionate. The IA, along with many other industry stakeholders and market participants, welcomed the European trilogue agreement allowing for a postponement of mandatory buy-ins along with the subsequent no-action letter published by ESMA. Mandatory buy-ins (MBIs) as legislated posed many risks for market participants and potentially unintended consequences that still hold true today as highlighted in the Commissions’ impact assessment , including a negative impact on liquidity and a disproportionate operational footprint and cost. Although the CSDR Review proposal addresses or partially addresses some of the concerns around mandatory buy-ins such as an introduction of a pass-on mechanism and clarification on asymmetry, most of the prior raised industry concerns remain. Taking into consideration our members on-going feedback and the consequences as outlined in the impact assessment we now advocate that mandatory buy-ins should be completely de-prioritised. We understand and agree with the approach to improve settlement efficiency and are committed to collaborating with all market stakeholders to ensure that the cash penalty regime is applied fairly. Should settlement rates not meet the appropriate levels as laid out in the CSDR proposal we would first ask regulators to consider whether cash penalties have been applied across the custody chain and given sufficient time to take effect, and in the second instance recommend a recalibration of cash penalties. Further feedback can be found in the attached file.
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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

Please find attached the Investment Association's response to the Commission consultation on MiFID II research.
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Response to Integration of sustainability risks and factors related to alternative investment fund managers

6 Jul 2020

Overarching Comment: As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the pursuit of certain sustainability objectives. We are committed to the growth and development of sustainable finance and support European policymakers’ demonstration of global leadership. Specifically, we welcome the Sustainable Finance Package with its broad objectives to 1) reorient capital flows towards sustainable investments, 2) manage financial risks stemming from ESG issues; and 3) foster transparency and long-termism in financial and economic activity. We thank the Commission for this opportunity to provide feedback on the Draft amendments to the Delegated Regulation (EU) No 231/2013 as regards sustainability risks and sustainability factors to be taken into account by Alternative Investment Fund Managers We welcome these efforts to ensure that firms take account of material sustainability risks in their processes and organisational requirements. We are particularly supportive of these measures being reflective of a principles-based approach when it comes to the incorporation of sustainability considerations within a firm’s processes, systems and controls. We support this approach as it ensures flexibility and therefore, more efficient applicability for firms as these differ in size, internal organisation and the nature, scope and complexity of the business conducted. We also welcome the clarity that has been brought to the definitions of “sustainability factors” and “sustainability risks” and the alignment of these with the definitions set out in Article 2 point (22) of Regulation (EU) 2019/2088. We note that the overall proposals help to clarify where sustainability factors should be taken into account by Alternative Investment Fund Managers (‘AIFMs’) as part of their duties towards investors across the entity processes, systems and internal controls as well as within risk management process and adequate resources and expertise for the effective integration of sustainability risks. However, despite this broad support, we have some outstanding concerns around the drafting which we seek to resolve below, including specific drafting suggestions. Summary of Key Issues: 1. Interconnectedness of the sustainable finance regulations • It is important to take a holistic view of the different component parts of the Sustainability Finance Action Plan and how they interact. We will only be able to assess the effectiveness of the changes across the piece once all new aspects have had time to bed in, given that there are issues with sequencing as it currently stands. 2. Sustainability risk assessment • Concerns around data availability and the need to recognise the importance of qualitative assessment • Need to ensure proportionality of sustainability risks alongside other risks 3. Proposal to include principal adverse impacts in due diligence process • Concerns around misalignment with other parts of the package, which take a less prescriptive approach and instead are predicated on the importance of transparency and investor choices (Regulation (EU) 2019/2088) • Possible conflicts with investment managers’ duties to act in the best interested of investors Our detailed comments, alongside proposed amendments, are included in the attached document. We would like to thank the Commission again for this opportunity to provide feedback on the draft amendments and hope our comments will positively contribute to the effort to include sustainability factors and risks considerations within existing Directives and Regulations.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

Overarching Comment: As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the pursuit of certain sustainability objectives. We are committed to the growth and development of sustainable finance and support European policymakers’ demonstration of global leadership. Specifically, we welcome the Sustainable Finance Package with its broad objectives to 1) reorient capital flows towards sustainable investments, 2) manage financial risks stemming from ESG issues; and 3) foster transparency and long-termism in financial and economic activity. We thank the Commission for this opportunity to provide feedback on the draft amendments to the Delegated Regulation (EU) 2017/565 as regards the integration of sustainability factors, risks and preferences into certain organisational requirements and operating conditions for investment firms. The integration of sustainability risks, factors and preferences into organisational requirements and operating conditions for investment firms is a key step towards ensuring: • Firms take account of material sustainability risks across their processes • The sustainability preferences of investors are considered across the distribution chain. Nevertheless, we have some concerns around aspects of the drafting, specifically whether it will achieve the Commission’s objectives. We set these out in more detail below – alongside proposed amendments – in an attempt to help achieve the goals of the Action Plan in practice. Summary of Key Points: 1. Suitability Assessment and the definition of “Sustainability preferences.” • We welcome clarification of the hierarchy of assessment criteria and grandfathering • We have serious concerns about the definition of “sustainability preferences”. The proposed definition narrows the universe of sustainability-related products beyond the categories set out in Regulation (EU) 2019/2088. It also reduces the scope of investment approaches and products which could be offered to investors in line with their needs and goals. 2. Integrating sustainability risks and factors • We have concerns around data availability and the need to recognise the importance of qualitative assessment • Sustainability risks should be considered alongside other risks Our detailed comments, alongside proposed amendments, are included in the attached document. We would like to thank the Commission again for this opportunity to provide feedback on the draft amendments and hope our comments will positively contribute to the effort to include sustainability risks and preferences within existing Regulations.
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

6 Jul 2020

Overarching Comment: As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the pursuit of certain sustainability objectives. We are committed to the growth and development of sustainable finance and support European policymakers’ demonstration of global leadership. Specifically, we welcome the Sustainable Finance Package with its broad objectives to 1) reorient capital flows towards sustainable investments, 2) manage financial risks stemming from ESG issues; and 3) foster transparency and long-termism in financial and economic activity. We thank the Commission for this opportunity to provide feedback on the Draft amendments to the Directive 2010/43/EU as regards the sustainability risks and sustainability factors to be taken into account for Undertakings for Collective Investment in Transferable Securities (UCITS). We welcome these efforts to ensure that firms take account of material sustainability risks in their processes and organisational requirements. We are particularly supportive of these measures being reflective of a principles-based approach when it comes to the incorporation of sustainability considerations within a firm’s processes, systems and controls. We support this approach as it ensures flexibility and therefore, more efficient applicability for firms as these differ in size, internal organisation and the nature, scope and complexity of the business conducted. We also welcome the clarity that has been brought to the definitions of “sustainability factors” and “sustainability risks” and the alignment of these with the definitions set out in Article 2 point (22) of Regulation (EU) 2019/2088. We note that the overall proposals help to clarify where sustainability factors should be taken into account by Undertakings for Collective Investment in Transferable Securities (UCITS) management company as part of their duties towards investors across the entity processes, systems and internal controls as well as within risk management process and adequate resources and expertise for the effective integration of sustainability risks. However, despite this broad support, we have some outstanding concerns around the drafting which we seek to resolve below, including specific drafting suggestions. Summary of Key Issues: 1. Interconnectedness of the sustainable finance regulations • It is important to take a holistic view of the different component parts of the Sustainability Finance Action Plan and how they interact. We will only be able to assess the effectiveness of the changes across the piece once all new aspects have had time to bed in, given that there are issues with sequencing as it currently stands. 2. Sustainability risk assessment • Concerns around data availability and the need to recognise the importance of qualitative assessment • Need to ensure proportionality of sustainability risks alongside other risks 3. Proposal to include principal adverse impacts in due diligence process • Concerns around misalignment with other parts of the package, which take a less prescriptive approach and instead are predicated on the importance of transparency and investor choices (Regulation (EU) 2019/2088) • Possible conflicts with investment managers’ duties to act in the best interested of investors Our detailed comments, alongside proposed amendments, are included in the attached document. We would like to thank the Commission again for this opportunity to provide feedback on the draft amendments and hope our comments will positively contribute to the effort to include sustainability factors and risks considerations within existing Directives.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

Overarching Comment As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the pursuit of certain sustainability objectives. We are committed to the growth and development of sustainable finance and support European policymakers’ demonstration of global leadership. Specifically, we welcome the Sustainable Finance Package with its broad objectives to 1) reorient capital flows towards sustainable investments, 2) manage financial risks stemming from ESG issues; and 3) foster transparency and long-termism in financial and economic activity. We thank the Commission for this opportunity to provide feedback on the Draft amendments to the Delegated Directive (EU) 2017/593 as regards the integration of sustainability factors and preferences into the product governance obligations. We particularly welcome the efforts to bring about alignment across regulations. Nonetheless, we have some concerns around aspects of the drafting, specifically whether it will achieve the Commission’s objectives. Summary of Key Points 1. Definition of “Sustainability preferences.” We have serious concerns about the definition of “sustainability preferences”. The proposed definition narrows the universe of sustainability-related products beyond the categories set out in Regulation (EU) 2019/2088. It also reduces the scope of investment approaches and products which could be offered to investors in line with their needs and goals. 2. Integration of sustainability factors within the product governance process We support European policymakers’ commitment to make Europe a global leader in sustainable finance and recognise the need to implement adequate practice through regulations as soon as possible. We would, however, like to highlight the practical complexities associated with the integration of sustainability factors within existing product governance processes. Our detailed comments, alongside proposed amendments, are included in the attached document. We would like to thank the Commission again for this opportunity to provide feedback on the draft amendments and hope our comments will positively contribute to the effort to include sustainability risks and preferences within existing Directives.
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Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which is of key importance in the promotion and development of sustainable finance throughout Europe and across the globe. The IA represents 250 UK-based investment management firms who collectively manage funds totalling EUR 8.1 trillion; of which EUR 2 trillion is on behalf of European clients. The UK asset management industry is a key part of both the UK and EU’s financial ecosystem, helping millions of individuals save for the long-term and enabling them to enjoy a more prosperous retirement. As significant investors in economies across Europe, it is our role to help investors and savers achieve their objectives – both financial and non-financial. Our members are witnessing growing demand from investors and savers for responsible investment strategies, as investors have become increasingly aware of the material impact sustainability issues could have on financial returns and on broader economic and financial stability. This trend has helped fuel the growth in the responsible investment market and our members are committed to continuing to promote and develop sustainability and responsible investment in all of its forms. The IA therefore welcomes the Commission’s Sustainable Finance Package with its broad objectives to 1) reorient capital flows towards sustainable investments, 2) manage financial risks stemming from ESG issues; and 3) foster transparency and long-termism in financial and economic activity. As this is a comprehensive and far-reaching Package, it is vital that the scope of each of the individual Proposals is clarified and that they work harmoniously with each other to progress this broad agenda. The European Commission should also consider the global implications of its Proposals. A lack of coordination between different approaches addressing taxonomy and disclosure, both within the European Commission and across different global initiatives, could have unintended consequences which may risk putting a brake on existing economic activities that already contribute to a more sustainable economy, as well as on further innovation and growth. The IA supports the European Commission’s commitment to be a global leader in sustainable finance and stands ready to work with the Commission and other key stakeholders to progress this agenda and boost the role of finance in achieving both a well-performing economy and one that also delivers on environmental and social goals. Please find our full response attached.
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Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which will be of key importance in the promotion and development of sustainable finance throughout Europe and across the globe. The IA represents 250 UK-based investment management firms who collectively manage funds totalling EUR 8.1 trillion, of which EUR 2 trillion is on behalf of European clients. The UK asset management industry is a key part of both the UK and EU’s financial ecosystem, helping millions of individuals save for the long term and enabling them to enjoy a more prosperous retirement. As significant investors in economies across Europe, it is our role to help investors and savers achieve their objectives – both financial and non-financial. Our members are increasingly witnessing a demand from investors and savers to take into account sustainability and responsible investment strategies. This trend has helped fuel the growth in the responsible investment market and our members are committed to continuing to promote and develop sustainable finance. Our members fully support the aim of the Disclosures Proposal to increase transparency and enable investors to choose investment products and services with greater clarity and comparability. It is our firm view that any disclosures relating to sustainable investment and sustainability risks should aim to improve transparency with respect to both investment products with particular sustainability objectives and the incorporation of ESG factors into investment decision-making. To ensure that disclosure practices convey genuinely meaningful information in the growing sustainable finance marketplace, the IA believes it is important to develop principles for disclosure, rather than an overly prescriptive approach that could risk making disclosures a tick-box exercise. Regarding the disclosure of remuneration policies, we recognise the disincentives that remuneration policies aligned with short term gain can create in our investee companies. We are therefore supportive of aligning remuneration policy with the delivery of sustainable, long term returns for any company, including financial institutions like asset management firms. The IA supports the European Commission’s commitment to be a global leader in sustainable finance and stands ready to work with the Commission and other key stakeholders to progress this agenda and boost the role of finance in achieving both a well-performing economy and one that also delivers on environmental and social goals. Please find attached our full response.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

The Investment Association (IA) thanks the Commission for the opportunity to comment on proposed changes to the MiFID II Suitability Assessment. Asset managers are increasingly seeking to integrate an assessment of environmental, social and governance (ESG) factors in their investment process and decisions and to monitor and mitigate their risks and opportunities, where these factors are deemed to have a material impact on performance. Along with integrating material ESG factors into the investment decision-making process, asset managers often actively engage with companies to identify and reduce ESG risks in order to ensure they remain a sustainable long-term investment proposition. This will include engagement on not just the company’s governance, but also on the company’s management of social and environmental risks, such as climate change and human capital development. As asset managers, it is our role to help end investors achieve their goals and objectives – both financial and non-financial – as well as contributing to economic growth through the efficient allocation of capital. We also recognize the key part that our industry can play in signposting opportunities/products for investors that contribute to sustainable growth and in the development of innovative products to contribute to such goals. We stand ready to work together with the Commission and other key stakeholders to progress the sustainable finance agenda in its aim of boosting the role of finance in achieving a well-performing economy that delivers on environmental and social goals as well. We are of course supportive of efforts to align investments with investors’ preferences and for asset managers to take account of sustainability risks. However, we have a number of concerns around possible unintended consequences arising from certain aspects of the current drafting. Below is a summary of our key concerns. Please see attached file for our full response. 1. Scope of the Definitions (Article 1(1)) We are concerned that the definitions as set out in Article 1(1) scope sustainable investing too narrowly. It is of greatest importance that the proposed amendments to the MiFID II Suitability Assessment reflect that ESG considerations extend beyond clients’ preferences for a particular sustainable investment and we would stress the crucial role that the consideration of all relevant and material environmental, social and governance risks and opportunities play in meeting investors’ needs and in growing sustainable finance. 2. Interaction with the Proposal for a new Sustainable Finance Taxonomy We have concerns around the interaction between proposed changes to the Delegated Act and the Proposal for a new sustainable finance taxonomy. It is imperative that industry receives clarity on the interaction between the amended Delegated Act and the Proposal for a new sustainable finance taxonomy and that asset managers are able to take as their reference existing best practice where a Taxonomy does not yet exist. 3. Hierarchy of Risks In the interests of protecting investors, we would stress the importance of treating ESG considerations proportionately, alongside other relevant risks. 4. Most suitable products vs suitable products Recital 9 of the draft MiFID II delegated regulation should refer to “suitable products” not “most suitable products”. 5. Information Flow We have concerns around the mechanics of the process needed to carry out the proposed requirements. It is unclear how we can ensure the necessary information flow, where there are no rules to facilitate this on the part of the product manufacturer.
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Response to EU small listed companies Act

21 Jun 2018

The Investment Association is delighted to provide input to your consultation on the proposed amendments to MiFID II, the Market Abuse Regulation and the Prospectus Regulation. Please see our comments in the attached letter.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

The Investment Association welcomes the opportunity to provide feedback on the Commission's proposed Implementing Regulation concerning shareholder identification and the transmission of information to facilitate the exercise of shareholders’ rights under the amended Shareholders Rights Directive II. Our comments are provided in the attached PDF document.
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Response to Review of the appropriate prudential treatment for investment firms

8 Mar 2018

The Investment Association (IA) is the trade body for the UK investment management industry representing £6.9 trillion of assets managed by more than 230 members. Our member firms include managers of a wide range of asset classes for a wide range of clients, including institutional funds, authorised unit trusts and open-ended investment companies. More than a third of the investments managed in the UK comes from overseas clients and it is more evident than ever that the UK continues to be Europe’s leading centre for international investment management. IA members are European and global firms and will be directly affected by the proposed new prudential framework irrespective of whether the UK leaves the European Union or not. We are, therefore, grateful for the opportunity to provide feedback to the Commission’s legislative proposals. The IA supported the development of a new prudential framework for investment firms from the very beginning, when EBA published its first report on the subject, which was prepared in response to the Commission’s call for advice of December 2014. We supported the conclusions and recommendations of the EBA report, particularly concerning the development of a prudential regime for “non-systemic” investment firms and we congratulate the Commission on its balanced and helpful legislative proposals. The EBA report highlighted very clearly a number of issues with the current CRD/CRR regime and we welcome that the Commission addressed these points and maintained the EBA approach. There are, however, a number of areas where we believe the proposals would benefit from amendments or further clarification. We comment on these remaining issues in our position paper, which you will find attached.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

The Investment Association is the trade body for the UK asset management industry representing £6.9 trillion of assets managed by more than 240 members. Our member firms include managers of a wide range of asset classes for a wide range of clients, including institutional funds, authorised unit trusts and open ended investment companies. More than 1/3 of the investments managed in the UK comes from overseas clients and more evident than ever the UK continues to be Europe’s leading centre for international investment management. Many members of the Investment Association are European and global firms and will be directly affected by the proposed changes to the European System of Financial Supervision. The Investment Association has been strongly supportive of the creation of a harmonised European supervisory framework, with European authorities cooperating closely with national supervisors to ensure a well‐functioning supervisory system. We, therefore, welcome the opportunity to comment on the Commission’s proposal to review the European System of Financial Supervision ahead of the legislative process following the publication of the Commission’s proposal. Please see our full position paper attached
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

15 Sept 2017 · CMU mid-term review, PEPP, MiFID II and sustainable finance

Response to Further amendments to the European Market Infrastructure Regulation (EMIR)

8 Sept 2017

Executive Summary The Investment Association (’The IA’) thanks the European Commission for the opportunity to respond to the Proposal of 13 June 2017 as regards the procedures and authorities involved for the authorisation of CCPs and requirements for the recognition of third-country CCPs (‘The Proposal’). First, we would point out that The IA shares the Commission’s key objectives of ‘safeguarding the safety and efficiency of CCPs that are of systematic relevance to EU markets and enhancing financial stability in the EU, without undue fragmentation of the global system’. Furthermore, we support the Commission’s commitment to proportionality such that any changes to the EMIR Regulation do not impose ‘excessive costs for market participants’, as these filter down to end users, including ordinary consumers saving for their pensions in the EU. In fact, The IA membership manages 37% of Europe’s (ex-UK) assets, much of which relates to pension provisions. Given our commonalities in these key respects, we have been compelled to highlight to the Commission the undue damage that the proposed location policy could inflict on EU institutions, end users in the EU and the EU real economy. To reiterate the response in our letter of 5 June, we are supportive of efforts to ensure effective supervision of critical financial market infrastructures and of close cooperation between supervisory authorities for the benefit of EU financial stability and that of the wider global system. However, we cannot support restricting the clearing of derivatives transactions of EU firms to the EU, which would have a number of negative unintended consequences across EU financial services, the EU real economy and the wider global financial system. Our concerns focus mainly on the direct impact for end users, in particular, in the EU. This includes: - Market fragmentation leading to higher costs for end consumers - Fewer market participants in the resultant fragmented pools leading to increased systemic risk - Increased margin costs and their impact on end consumers Moreover, there would also be serious global implications and long term impacts for EU end users, namely: - The removal of competition leading to less pressure to innovate and drive down prices for consumers - Setting a dangerous precedent for other jurisdictions which could further fragment the global market in the future It is clear that the EU wants to bolster its financial stability and protect EU consumers, EU institutions and the EU real economy. It is also clear that it is the responsibility of EU authorities to consider means of mitigating possible systemic risks, given the changing state of Europe and the current landscape of the derivatives clearing market. Notwithstanding these considerations, we strongly urge the EU not to restrict access to clearing for EU institutions and clients. In the interests of protecting both the future of the global derivatives clearing market and the present EU real economy, it is imperative that the EU reconsider its Proposal to refuse the recognition of a CCP based solely on it being determined of ‘significant systemic importance’ irrespective of its adherence to EMIR requirements. Such an approach would lead to the undue fragmentation of the global system to both the immediate and long term harm of end clients in the EU. As an alternative approach, we urge the EU to consider the merit of adopting enhanced equivalence and supervisory provisions to monitor and mitigate potentially systemic risks and thereby safeguard the future of the EU financial system. Please find attached our full response for your review. We look forward to working closely with you and stand ready to assist in this very important matter.
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Response to EMIR Amendment

18 Jul 2017

Please see attached file.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

6 Apr 2017 · CMU, non-performing loan problem, sustainable finance.

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

30 Nov 2016 · Financial services agenda

Response to Financial Markets Infrastructure: Further one-year extension of the central clearing exemption for pension funds

28 Nov 2016

The Investment Association supports the proposal to extend the pension funds exemption from central clearing by a further year. As CCPs continue to demand only cash VM, the argument by which PSAs were originally exempted from the clearing obligation still stands. It is not in the interests of financial stability or the end client to expect PSAs to post only cash VM. The Commission’s report of 3 February 2015 on Article 89 conceded that it would be unreasonable to oblige PSAs to post cash VM. In particular, the report noted that the exemption was designed to avoid forcing PSAs to “hold cash reserves instead of higher yielding assets” and thereby reducing “the total amount paid out by the PSAs as retirement income”. Ideally, non-cash VM should be permitted more generally, if “haircut” appropriately to the collateral posted, but we recognise the significant operational challenges that this continues to pose to CCPs. Existing legislative restrictions on the ability of fund managers to convert fund assets to cash for use as VM make cash-only VM requirements even more challenging. For example, ESMA’s Guidelines on Exchange Traded Funds (ETFs) and other UCITS issues has significantly impaired UCITS’ ability to access cash via repurchase agreements (repos). Pension schemes provide an important social benefit to the economy and society by generating incomes for pensioners in their retirement. In order to generate this income, they are typically fully invested and minimise their allocations to cash. This reflects the long-term nature of their pension fund obligations and therefore to generate long-term returns. Mandatory clearing for pension funds would therefore introduce significant new liquidity and transformation risk as they would be forced to meet VM calls by either liquidating existing investments at very short notice (1 day) or attempting to repo their assets. This is a new risk for pension funds as they have previously been able to post VM in the form of government bonds or high quality corporate bonds. Pension funds would find it challenging to manage this liquidity risk in stressed market conditions. This is exactly when central clearing is meant to provide stability to the financial system. Only central banks have the ability to mitigate liquidity risk in these circumstances. Unlike banks, and to some extent CCPs with the recent developments, pension funds do not have access to central bank liquidity as the liquidity provider of last resort. This new liquidity risk would potentially have wider market implications. It would apply additional stress on a repo market that is already shrinking as a result of bank capital regulations. It would potentially exacerbate downward pressure on falling asset prices in stressed market conditions as pension funds sell out of their physical assets (such as bonds and equities) in order to meet the cash VM calls. All this, we believe, conflicts with EMIR policymakers’ objective of reducing risk and avoiding pro-cyclicality. Given the importance of the pensions exemption and policy-makers recognition of this issue in granting the exemption to PSAs, it is critical to ensure that the exemption is practically workable in the long term. We, therefore, support the Commission’s proposal to grant a further one year exemption as provided for under Article 85(2) of EMIR. Furthermore, we would suggest that the Commission continue to require that the exemption remain in place until such time as either it ceases to be unreasonable to oblige PSAs to post cash VM, or CCPs have built the capabilities to receive non cash VM – potentially indefinitely. As the exemption of the 16 August 2017 will be the final exemption provided for under EMIR, we suggest that the clearing exemption to PSAs is considered as part of the upcoming EMIR Review.
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

10 Oct 2016 · CMU

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

6 Jun 2016 · CRD IV review for investment firms

Meeting with Jonathan Hill (Commissioner)

18 Apr 2016 · Capital Markets Union

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

1 Mar 2016 · Capital Markets Union

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

19 Jan 2016 · OECD- BEPS

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

1 Oct 2015 · Financial Services Policy

Meeting with Jack Schickler (Cabinet of Commissioner Jonathan Hill)

26 Aug 2015 · CCP recovery and resolution

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

26 Jun 2015 · Markets in Financial Instruments Directive II

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

20 May 2015 · Markets in Financial Instruments Directive II/MIFIR

Meeting with Jonathan Hill (Commissioner)

8 May 2015 · Asset management/Capital Markets Union

Meeting with Jonathan Hill (Commissioner)

8 May 2015 · Financial Services Policy

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

25 Feb 2015 · Resolution of central counterparties (CCPs)

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

23 Feb 2015 · Capital Markets Union, transparency of disclosure and consumer protection

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and Fleishman-Hillard

2 Dec 2014 · European consumer protection in the field of investor disclosure