ESAs’ joint consultation paper on taxonomy-related sustainability disclosures

FFI response to consultation concerning  taxonomy-related sustainability disclosures

  • We support the use of harmonized financial product templates to inform customers about the product’s sustainability characteristics and whether the investments are aligned with the EU taxonomy.
  • The timeline between the finalization of these disclosure requirements and their expected implementation is too tight. Financial market participants should have at least six months to implement the new requirements after their publication.
  • Considering the vast diversity of the (sustainable) investment universe and different investment options, the templates should allow the financial market participants to more freely express their product’s investment strategy and other features. While maintaining the pre-determined information fields, the templates should also allow for a free description of the product.
  • We worry about information overload to customers, considering the already extensive mandatory product disclosure that they get.