Sustainable Finance Lobbying Overview: Invesco appears to have had mixed engagement on sustainable finance policy, generally supporting policy to improve corporate ESG disclosure and not supporting policy on investment decision-making.

Top-Line Messaging on Sustainable Finance Policy: Invesco appears to support urgent action to tackle climate change, and in 2021 Invesco joined the Net Zero Asset Managers initiative, supporting the global goal of reaching net zero emissions by 2050 or sooner. In 2020 comments to the European Commission, Invesco suggested that sustainable finance policy should encourage positive action but not restrict negative action.. In 2022 comments to the UK Department for Business, Energy, and Industrial Strategy (BEIS), Invesco welcomed government regulation on sustainable finance.

Position on Regulated Corporate ESG Disclosure: Invesco appears generally supportive of regulated corporate ESG disclosure, with some exceptions. In a 2020 white paper, Invesco advocated for increased ambition of the EU’s Non-Financial Reporting Directive (NFRD), and echoed this in comments on the European Commission’s review of the Directive in 2020. In a 2021 letter to the US Securities and Exchange Commission (SEC), Invesco also strongly supported regulated corporate ESG disclosure in line with TCFD guidelines and subject to third party auditing. In 2020 and 2021 comments to the UK Financial Conduct Authority (FCA), Invesco supported regulated disclosure in line with the TCFD. In a 2022 insights paper, Invesco also stated support for mandatory reporting frameworks in Singapore, India, and Hong Kong. However, in July 2022 comments on the International Sustainability Standards Board’s (ISSB) draft climate disclosure standards, Invesco took a more mixed position, advocating for phase-in of certain provisions including Scope 3 and scenario analysis disclosures. In August 2022, Invesco outlined objections to the proposed European Sustainability Reporting Standards (ESRS), advocating for the standards to closer more with the ISSB.

Position on Taxonomies and ESG Standards/Labels/Benchmarks: Invesco appears to have mixed positions on a taxonomy. Invesco commented on the EU Taxonomy to argue that the proposed 'green' thresholds were too stringent in a media article in 2019 and in feedback to the European Commission in 2020. In feedback to the Commission's Renewed Strategy in 2020 Invesco supported the expansion of the taxonomy to cover environmentally harmful activities but appeared to argue for an approach with a greater emphasis on the transition. In a 2021 white paper, Invesco appeared to advocate for weakening of the EU Taxonomy, suggesting that the current approach that penalizes assets that are not "green" puts the climate transition at risk. In comments to the UK BEIS in 2022, Invesco suggested that the UK Green Taxonomy should account for transitioning assets. A 2022 insights paper states support for government efforts to establish taxonomies in Asia.

In 2020 comments on the EU Renewed Strategy, Invesco supported verification for the EU Green Bond Standard and supported some of the Commission’s suggestions for new ESG labels but not others. In response to the UK FCA’s consultation on Sustainability Disclosure Requirements and investment labels in January 2022, Invesco supported and advocated for increased ambition for some proposed labels and standards, but advocated for the watering down of others. In June 2022, Invesco supported the "transition" labels included as part of the UK Sustainability Disclosure Requirements (SDR) proposal. In August 2022, Invesco took a mixed position on the SEC’s proposed categories for ESG-related funds, supporting the proposal but suggesting narrower criteria for inclusion in each category. Invesco did not support the SEC’s proposed expansion of the Names Rule and its 80% investment requirement to funds with names that suggest an investment strategy, including an ESG-related strategy, suggesting that disclosure is a better means to address fund greenwashing. In November 2022, Invesco outlined objections to the EU’s proposed quantitative thresholds for fund names using ESG or sustainability-related terms.

Position on Incorporating ESG Factors Into Investor Duties: Invesco appears generally unsupportive of incorporating ESG factors into investor duties. In feedback to the European Commission on the Renewed Sustainable Finance Strategy in 2020, Invesco did not appear to support adapting fiduciary duty to take into account adverse impacts on sustainability. In response to the ESA’s Sustainable Finance Disclosure Regulation (SFDR) consultation on investor ESG disclosure in 2020, Invesco argued against the stringency of the proposed regulation and suggested a principles-based approach instead, although welcomed the regulation in a website article in 2021. Invesco took a mixed position on the FCA’s proposed SDR and investment labels in June 2022, cautioning about a lack of available data but supporting disclosures for all investment products marketed in the UK. In August 2022, Invesco outlined several objections to the SEC’s proposed disclosures for investors about ESG practices, characterizing the proposal as “overly prescriptive” and opposing quantitative engagement disclosure requirements.

Industry Association Governance: Invesco has disclosed memberships to some, but not all industry associations, and has given little detail of the sustainable finance policy positions of these groups. Its disclosure omits mention of membership to some groups actively engaged on sustainable finance policy, including the Institute of International Finance (IIF) and the Securities Industry and Financial Markets Association (SIFMA).