FESE welcomes the opportunity to provide a response to the ESAs’ consultation on taxonomy related sustainability disclosures.
We support the approach of having only one set of RTS. We have observed some issues in the incoming regulations regarding discrepancies and overlapping requirements. Consolidating the SFDR and the Taxonomy Regulation RTS into one would therefore be very helpful to improve consistency.
We welcome the KPIs selected to measure taxonomy-alignment and believe that the approach proposed by the ESAs should grant enough flexibility for financial intermediaries to apply their calculation of KPIs and to evaluate the taxonomy-alignment of investee companies. However, we are concerned that limiting financial intermediaries to the same approach for all investees of a given product/fund could prevent them from selecting the most material KPIs based on the nature of investee companies’ businesses.