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19 February 2019

ALFI’s comments on ESMA’s consultation paper on integrating sustainability risks and factors in the UCITS Directive and AIFMD


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ALFI strongly supports the initiative of the Commission to promote sustainable finance. However, ALFI would like to point out that ALFI commented in October 2018 that the proposal required certain adjustments and clarifications for it not to be a missed opportunity.


The scope and definitions in the proposal were ALFI’s main concerns.

Indeed, while “sustainability risk” is at the core of the proposal (in last year’s consultation) it was not defined. ALFI is therefore pleased that ESMA has proposed a definition in the current consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD.

Indeed, a definition of “sustainability risk” is key as the concept needs to be defined because all market participants cannot be expected to understand it – at least not in the same manner. 

Generally speaking, ALFI agrees with ESMA’s suggestions to integrate sustainability risks and factors in the UCITS Directive and AIFMD through a high-level principle based-approach.

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© ALFI - Association of the Luxembourg Fund Industry


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