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Whilst we welcome an increase in transparency for customers, we anticipate that the proposals as they stand will most likely result in an additional cost for benchmark administrators. Transparency for investors could be enhanced without additional costs by defining the ESG minimum disclosure requirements on a more detailed level in the context of supporting standards and specifications.
In addition, the disclosure requirements should not differentiate even if the security is listed or not, as the same requirements should apply to both categories. There is a risk that should such a distinction be made, it would act as a disincentive to listing and result in overall decreased transparency.