...we would like to stress that the new regulation gives rise to a number of inconsistencies, concerns, and doubts which we believe will hinder its implementation.
While the EBF welcomes the ultimate objective of the European
legislators and supervisors of promoting sustainable development, as a
general remark, we would like to stress that the new regulation gives
rise to a number of inconsistencies, concerns, and doubts which we
believe will hinder its implementation.
- On timing: Misalignment of the application
timelines of SFDR and MIFIR rules on integrating sustainability will
create great legal uncertainty for investment firms and a huge confusion
for their clients. We therefore fully support the European joint
industry proposal to postpone the implementation of the MiFID II
delegated act until 1 July 2023. We believe ESMA should allow for a
sufficient broad implementation period following the publication of the
final guidelines.
- Regarding the scope, we don’t support a “one-size
fits all” approach as proposed which does not take into account the
different nature and characteristics of certain financial instruments,
especially for instruments that are not under the scope of SFDR and
Taxonomy Regulations.
- Need for greater flexibility: we believe that ESMA’s suggested approach is excessively complex.
- Data availability: the new rules on sustainability
preferences will have a big impact not only on investment firms subject
to MiFID but also on producers manufacturers of financial instruments
(e.g. companies and asset managers) that will need to provide a large
amount of data that is needed in order for investment firms to fulfill
their requirements.
EBF
© EBF
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