Sustainable Finance Lobbying Overview: BNP Paribas appears to be generally supportive of regulation on sustainable finance, with subsidiary BNP Paribas Asset Management contributing a significant proportion of its policy engagement. In general, engagement from BNP Paribas Asset Management appears to be more supportive on sustainable finance policy than the group-level engagement.

Top-line Messaging on Sustainable Finance Policy: BNP Paribas Asset Management has called for reform to achieve a sustainable financial system and has stated support for limiting global warming to 1.5 degrees. Both BNP Paribas and BNP Paribas Asset Management have also advocated for action to reach net-zero by 2050, participating in a number of investor initiatives advocating to EU leaders and the UK’s Prime Minister in 2020 and to governments in 2021 and 2022. BNP Paribas Asset Management has also advocated for the post-2020 global biodiversity framework to mandate the alignment of financial flows with biodiversity goals. Since 2018, BNP Paribas Asset Management has consistently supported the aims of the EU's Sustainable Finance Action Plan, with some examples of support from other parts of the group including BNP Paribas Securities Services. It has urged the Commission to "accelerate the systemic sustainability transition of the EU financial sector" and called for European institutions to lead the private sector in delivering the goals of the Paris Agreement.

Position on Taxonomies: BNP Paribas Asset Management was particularly engaged in promoting the taxonomy in 2018-20. This has included on its website and social media posts. According to minutes accessed through a Freedom of Information request, BNP Paribas advocated for a rigorous science-based taxonomy in a meeting with the European Commission in 2019 and BNP Asset Management continued to do so in corporate reporting in 2021. However, in feedback to the European Commission's consultation on the Renewed Sustainable Finance Strategy and to the European Banking Authority (EBA) in 2020, BNP Paribas opposed the development of a taxonomy of environmentally harmful activities. In response to the Commission in 2021, BNP Paribas also argued for taxonomy disclosures to be phased in and not to be too granular in a first stage. In a 2022 website article, BNP Paribas CIB offered broad support for an Australian sustainable finance taxonomy.

Position on ESG Standards, Labels & Benchmarks: In feedback to the European Commission's consultation on the Renewed Sustainable Finance Strategy in 2020, BNP Paribas supported the verification for the EU Green Bond Standard, and suggested that an ESG label or range of labels targeted to all investors should be established. However, it did not support the development of a broader ESG benchmark by the Commission and suggested minimum standards instead.

Position on Integrating ESG into Investor Duties: BNP Paribas Asset Management has supported clarifying investor duties to include ESG issues and has also strongly advocated for policies which would implement this, including ESG investor disclosure and integrating ESG preferences into suitability assessments. However, in response to the ESAs’ consultation on investor ESG disclosure in 2020, BNP Paribas Asset Management argued against the stringency of the proposed indicators. In more recent 2020 blogs, both BNP Paribas Asset Management and BNP Paribas Securities Services supported the EU’s disclosure regulation. In feedback to the European Commission in 2020, BNP Paribas further supported incorporating adverse ESG impacts into fiduciary duty and considering members’ ESG preferences in pension schemes. In response to the Bank of England on climate change financial risks assessments in 2020, BNP Paribas argued for less granularity in scenario analysis. In a 2022 website article, BNP Paribas Asset Management offered broad support for the Sustainable Finance Disclosure Regulation (SFDR) and MIFID II and engaging clients on their ESG preferences, although it did highlight that these policies were challenges for the industry “given their complexity”.

Position on Regulated Corporate ESG Disclosure: BNP Paribas Asset Management endorsed a statement to policymakers for an ambitious review of the Non-Financial Reporting Directive (NFRD) in 2020. In a 2021 letter to the SEC, BNP Paribas strongly supported mandatory ESG disclosure, including disclosure on Scope 1, 2, and 3 emissions. However, in its 2022 response to the SEC, it suggested some more flexibility, calling certain aspects "overly prescriptive". It also supported ambitious global climate-related disclosures in response to the International Sustainability Standards Board (ISSB), such as a "double materiality" approach. In response to the European Commission on the Corporate Sustainability Reporting Directive (CSRD) in 2022, BNP Paribas also argued that the disclosure requirements were "overly complex”. BNP Paribas Asset Management advocated for increased ambition to the Canadian Securities Administrators’ Draft Regulation on disclosure of climate-related matters in 2022. More recently, BNP Paribas and BNP Paribas Asset Management have advocated for regulated corporate disclosure around biodiversity in website articles and in joint statements by the financial sector in 2022. BNP Paribas Asset Management has also advocated for disclosure mandatory implementation of the TCFD and 1.5 pathway-aligned transition plans in 2022 and 2021.

Position on the integration of ESG factors into prudential regulation and risk management: In 2020, BNP Paribas supported the incorporation of ESG risks but warned against mandatory prudential treatment in response to the Commission. In a consultation response to the Bank of England in 2020, BNP Paribas also argued for less granularity on the assessment of the impact of climate change in banks and insurers. In response to the European Banking Authority’s (EBA) proposal on ESG risks in 2021, BNP Paribas cautioned that the number of proposed templates was too complex and against the disclosure of Scope 3 and exposure of carbon-intensive firms. In a website article in 2022, BNP Paribas CIB offered broad support for efforts to introduce climate-related financial risks into regulation in Australia. Also in 2022, BNP Paribas Asset Management supported the integration of climate risks into scenario analysis as part of Solvency II. However, in response to the EBA in 2022 on the introduction of environmental risks into a prudential framework, BNP Paribas cautioned that regulatory efforts should focus on risk management and not disincentivise financing the transition. In a meeting with the Office of the Comptroller of the Currency (OCC) in 2022, BNP Paribas was one of the representatives of the Bank Policy Institute (BPI), which highlighted “challenges they foresaw in implementing certain of the draft Principles” referrin to the OCC’s draft Principles for Climate-Related Financial Risk Management for Large Banks.

Lobbying Transparency: BNP Paribas has disclosed all relevant policy positions in the EU, but does not appear to disclose in other regions, such as US and Canada. However, subsidiary BNP Paribas Asset Management has clearly disclosed all sustainable finance policies relevant to its operations. The group level disclosure lists trade association memberships without any further details on indirect policy engagement, while BNP Paribas Asset Management has clearly described trade association memberships, with positions taken by the company within the trade associations and ability to shape policy positions. Disclosure on direct and indirect policy engagement appears to be more fragmented across the rest of the group.