Date: 1st September 2020

This document contains the response of BETTER FINANCE to the European Commission’s online survey (public consultation) concerning the consultation on the renewed sustainable finance strategy.

BETTER FINANCE considers that the regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 is extremely important to clarify fiduciary duties and increase the transparency of the disclosure of sustainability risks. However, in order to be effective, the disclosure regulation needs to be harmonised with the taxonomy regulation and the non-financial reporting directive. Considering that one of the major issues is the lack of a common definition of sustainable investments, it necessary to link how asset managers define sustainable investments with the taxonomy-compliant activities in order to avoid any regulatory divergences. In this regard, we advise to strengthen this link in the draft of Regulatory Technical Standards (RTS).