Bank Policy Institute

05/30/2025 | Press release | Archived content

Joint Third-Country Associations’ Response to the Commission’s Call for Evidence to inform the Impact Assessment for the intended SFDR Review proposal

The Swiss Finance Council (SFC) and the Bank Policy Institute (BPI) represent financial institutions headquartered outside the EU and invested in the EU. Our members operate as retail investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis. As such, they are directly subject to the requirements of the current Sustainable Finance Disclosures Regulation (SFDR).

We strongly support efforts to build an effective framework for sustainable finance to facilitate the transition to a sustainable economy, and we credit the EU for its leadership in the sustainable finance space.

Against this backdrop, we welcome the Commission's intent to review the SFDR with a view to improving the functioning of the framework, addressing undue burdens as well as simplifying and streamlining requirements.[1] Building on individually submitted responses to the Commission's targeted consultation in 2023, the undersigned associations would like to offer their views on the changes considered by the Commission, as outlined in the Call for Evidence to inform the Impact Assessment ahead of the eventual legislative proposal.

Facilitating global sustainable investment flows through interoperable frameworks

The undersigned associations fully endorse the Commission's findings that the revised SFDR should "take better account of the international reach and exposures of investments; and help to direct investment towards diverse sustainability-oriented aims while avoiding greenwashing"[2].With this in view, we would like to emphasise that jurisdictions outside the EU have implemented or are in the process of developing their own disclosure and classification frameworks for sustainable investment products, including in certain cases product labels, such as the UK FCA's Sustainability Disclosure Requirements (SDR) regime or the Swiss Federal Council position on greenwashing supplemented by the industry's self-regulation framework on transparency and disclosure for sustainability-related collective assets. In this context, we call on the European Commission to ensure that changes introduced to the SFDR take into consideration this broader regulatory ecosystem and are accordingly designed in a way which is interoperable with the frameworks of other international jurisdictions, to maximise international capital flows directed at financing the transition.

To read the full comment letter, please click here, or click on the download button below.

20250530_Joint Association Response to SFDR CfEDownload

[1] European Commission - Call for Evidence (CfE) for an Impact Assessment for a revision of EU rules on sustainable finance disclosure, p.2.

[2] Ibid, p.2.

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