State Street appears to have had mixed engagement on sustainable finance policy overall, generally not supporting stringent regulations on asset managers. In 2021 State Street Global Advisors joined the Net Zero Asset Managers initiative, a coalition of asset managers that supports the goal of net-zero emissions by 2050 or sooner. In a 2021 LinkedIn post, CEO Ron O’Hanley advocated for achieving a zero-carbon economy by 2050. State Street appears to have a mixed position on the need for sustainable finance regulation, supporting regulatory action in some cases, like Australia, and voicing more caution in others, like the EU’s Renewed Strategy.

Since 2019, State Street has become more supportive of regulation that would mandate climate disclosure by the corporate sector, but still appears skeptical of stringent regulation on the financial sector. In a 2021 insights paper State Street appeared to support mandatory carbon emissions disclosure for the EU, and in a 2021 letter to the SEC it called for similar mandatory disclosure for issuers in the US. However, in 2021 comments to the FCA on its consultation on climate-related disclosures by asset managers, life insurers, and pension providers, State Street Global Advisors advocated for extending the reporting deadline and called Scope 3 disclosure mandates “premature.” After the SEC released its proposed climate disclosure rule in March 2022, State Street released an article that took a supportive position toward the proposal, calling it a “watershed moment.”

State Street appears to have taken mixed positions on a taxonomy. State Street supported the EU's taxonomy in a 2019 consultation response to the UK's FCA and in an insights article from 2021 State Street Global Advisors reiterated this support. However, in feedback to the Commission on its Renewed Strategy in 2020, State Street opposed the expansion of the taxonomy to cover environmentally harmful activities, and in a 2021 consultation on the review of the AIFMD, State Street characterized the taxonomy as overly prescriptive.

In March 2020, State Street Global Advisors released a guide to the EU's climate benchmarks which was generally supportive of the policy with minor concerns around data availability. In feedback to the Commission in 2020, State Street supported verification for the EU Green Bond Standard and supported some of the Commission’s suggestions for new ESG labels but did not support others. In a response to the FCA’s discussion paper on sustainability disclosure requirements and investment labels in January 2022, State Street Global Advisors did not support the proposed classification system for investment products and cautioned against imposing thresholds for fund categories.

In feedback to the Commission in 2020, State Street was not supportive of incorporating adverse ESG impacts into fiduciary duty or the Commission’s suggestions concerning further integrating ESG preferences in advice to clients. In response to the ESA’s SFDR consultation on investor ESG disclosure in 2020, State Street Global Advisors argued for a less prescriptive approach, and in the 2021 review of the AIFMD State Street opposed mandatory consideration of ESG factors in investor duties. Alternatively, in comments to the US Department of Labor in 2020, State Street strongly opposed regulation that would limit fiduciaries' ESG investing and voting on ESG issues. In October 2021, State Street issued a press release stating support for the Department of Labor’s proposed ESG fiduciary investing rule, a proposal that would reverse Trump-era regulations limiting ESG investing and voting, but in its comments on the proposal State Street Global Advisors asked the Department to alter language and remove references to ESG, cautioning against an implied requirement to consider ESG factors in all cases.

State Street has appeared not to support incorporating ESG factors into risk management and prudential regulation. In comments to the Basel Committee on Banking Supervision in 2022, State Street advocated for flexibility in the Committee’s proposed risk management principles and requested that certain provisions on climate risk management and scenario analysis be withdrawn. In comments to the Canadian Office of the Superintendent of Financial Institutions in 2021, State Street suggested that it was premature to mandate additional climate-related stress tests and emphasized that scenario analysis is still in its “early stages.”

State Street has a webpage dedicated to public policy engagement but lacks a section specific to sustainable finance policy. State Street has disclosed principal U.S. trade association membership but has not given details about the sustainable finance policy positions of these organizations or any actions it has taken to address misalignment, and has not listed membership to non-U.S. associations.