European Commission Taxonomy Article 8 Delegated Act:
EBF response

European Commission Delegated Act on the Taxonomy Article 8: EBF response

Please find below a few key points of the EBF response on the European Commission Delegated Act on the Taxonomy Article 8:

• Need for alignment between the CSRD and Article 8 Delegated Acton scope and application timelines (including any possible transition periods).
• The GAR should only cover assets for which the information is publicly available.
• Financial institutions’ disclosure can only occur with 1 year time lag following the disclosures of financial and nonfinancial clients and counterparties.
• KPIs should be defined consistently. If certain activities are excluded from the numerator on the basis that it is not possible to assess their sustainability or irrelevance, they should also be excluded from the denominator.
• EBF is proposing an alternative approach that will achieve the same objectives as the proposed DA but provides for a better and fairer comparison of GAR, while providing full transparency to the market based on data availability and feasibility. While market participants will be in the position to calculate any ratio based on the full disclosure, the GAR will provide for comparable information on a more level playing field basis).
• Additional KPIs to be disclosed on a voluntary basis separately from GAR on taxonomy alignment of exposures to non-CSRD entities that are reporting on a voluntary basis will allow entities to report on the progress.