Since its implementation in 2021, there has been criticism on the effect of the EU Sustainable Finance Disclosure Regulation (SFDR). In 2023, the European Commission therefor initiated a consultation on the SFDR.

Both the Dutch financial market authority AFM and Triodos IM published a position paper on how to improve the SFDR. Rosl Veltmeijer discusses the overlap and the differences between the two positions with Zoë du Chattel, Senior Supervision Officer at AFM and Hadewych Kuiper, Managing Director at Triodos Investment Management.

SFDR improvement proposals

Triodos Investment Management proposes a simple, clear and comparable categorisation system that informs all investors about the sustainability efforts of a financial product.

The AFM proposes improvements to the framework to make it more meaningful to investors and the objective to reorient capital flows to where impact is made.

An important conclusion is that both the AFM and Triodos IM are in favour of a minimum level of disclosure for all funds to create a level-playing field. Both also propose to convert the current transparency regime into a labelling regime so retail investors can easily compare products and see which is the more sustainable.

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The EU Sustainable Finance Disclosure Regulation (SFDR) was one of the first regulatory initiatives stemming from the 2018 EU Sustainable Finance Action Plan. It is a sustainability-related disclosure framework for financial market participants and financial advisers focusing on the integration of sustainability risk and the consideration of adverse sustainability impact in the investment process.

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