Consultation on the SFDR regulation: Impact France's recommendations to improve but not give up

As part of the consultation launched by the European Commission on the SFDR (Sustainable Finance Disclosure Regulation), which will come into force in 2021 and aims to strengthen the transparency of financial players on the environmental, social and governance impacts of their investments, Impact France has submitted several operational recommendations based on feedback from its financial members.

The SFDR regulation has become an essential cornerstone of sustainable finance in Europe. It has made it possible to impose greater transparency on how investors take ESG criteria into account, to establish a common language across the market, and to catalyze a dynamic of commitment even among players historically little mobilized.

But major limitations remain. The framework remains too complex for retail investors, definitions of key concepts lack clarity, and the reporting burden is unevenly distributed, to the detriment of the most virtuous funds. Unlisted players, particularly in venture capital and impact investing, are particularly penalized by unsuitable obligations.

To reinforce the impact of the regulation, Impact France recommends :

• Clarify and harmonize key definitions (sustainable investment, PAI, etc.) and align them with other European frameworks (CSRD, taxonomy).
  
  
• Adapting requirements to the realities of each player, especially the smaller or unlisted ones.
  
  
• To better supervise non-sustainable funds, by imposing minimal reporting on their negative impacts.
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• Go beyond mere transparency, by introducing requirements for exclusion or progress.

Sustainable finance cannot simply inform: it must transform. That's the message Impact France wanted to convey in this consultation, calling for clearer, fairer and more ambitious regulation to help transform business models.

See the answers