EBF response to the EC Call for evidence: EBF calls for a fitness check on sustainable finance framework
BRUSSELS, 4 December 2023 – The reporting of ESG information as such is relatively new but early experience already shows material implementation and operational challenges not only with the data collection, analysis, monitoring and control for which massive investments in IT and operational processes were necessary, but also the need for simplification given that the Sustainable Finance (SF) Framework has become excessively complex, inconsistent and difficult to apply. As a matter of urgency, the Commission should not only focus on the identification of reporting requirements that may be considered overwhelming, obsolete, unclear or costly, but also allow for pragmatic approaches and consider providing common tools that will substantially reduce the cost of individual reporting and increase data availability
A ‘usability’ omnibus legislative proposal early in the next legislature should be considered. This proposal should address the following aspects:
Simplification of the regulatory requirements and increase of their usefulness, usability and practical application of the framework should be an overarching aspect and objective of the revision. Given that some parts of the EU Framework are still in the making, any new ESG regulatory requirements need to be well articulated with all other pieces of ESG legislation, with attention paid to sequencing and timing to ensure that companies are able to fulfil their obligations. Attention must also be paid to the issue of regulatory overload and international developments, ensuring that the EU ESG regulatory reporting requirements are proportionate and do not threaten the competitiveness of EU businesses.
The EBF plans to issue a report on the usability of the SF Framework which will include concrete suggestions of improvement as well as examples where the SF Framework could be simplified. Once finalized, we will be pleased to share with the European Commission and contribute to its efforts to increase the usability of the SF Framework. The EBF will be also contributing to the debate on the usability as members of the EU Platform on Sustainable Finance.
For more information:
Denisa Avermaete, Senior Policy Adviser – Sustainable Finance, D.Avermaete@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.