Sustainable Finance Lobbying Overview: Invest Europe appears to have fairly limited engagement on sustainable finance policy, but does not appear to support stringent regulatory intervention.
Top-line Messaging on Sustainable Finance Policy: Invest Europe has stated support for the EU's net zero by 2050 target in its 2021 Climate Ambition Statement. Invest Europe has consistently emphasized that any regulation should be "workable, proportionate and support Europe’s wider economic aims" and has also appeared to suggest that voluntary action by the private equity sector is largely sufficient in addressing sustainability risks. In feedback to the European Supervisory Authorities (ESAs) on greenwashing in 2023, it highlighted that market participants should not be penalized for having taken a “wrong” view regarding regulation and that that greenwashing does "not warrant its own regime".
Position on Taxonomies, and ESG standards and labels: In feedback to the Commission on the Renewed Sustainable Finance Strategy in 2020, Invest Europe suggested that public authorities should align spending with the taxonomy and supported its expansion to social issues. In the same feedback, Invest Europe appeared to support the creation of ESG labels for funds for professional investors with minor exceptions, such as costs. In 2022, it opposed a proposal by the European Securities and Markets Authority (ESMA) to introduce quantitative thresholds for fund names using ESG or sustainability-related terms, arguing that the introduction of these guidelines is not “within the powers of ESMA”.
Position on Integrating ESG into Investor Duties: In feedback to the Commission in 2020, Invest Europe appeared to oppose an expansion of fiduciary duty to cover adverse impacts of investments on sustainability issues. In response to the ESA’s Sustainable Finance Disclosure Regulation (SFDR) consultation on investor ESG disclosure in 2020, Invest Europe argued for a less prescriptive approach, including a reduced number of mandatory indicators. In multiple letters to the Commission during 2022-2023, Invest Europe made specific comments on alternative investment funds disclosures under Article 10 of the SFDR. Also in 2023, it encouraged the ESAs to delay the SFDR review and suggested that financial institutions should not be required to disclose non-material indicators under the ESRS.
Position on Other Sustainable Finance Policies: Invest Europe appears to be cautious about the use of prudential regulation to achieve sustainable finance goals. In feedback to the European Commission in 2020, Invest Europe was cautious about the review of the Non-Financial Reporting Directive (NFRD), arguing against the expansion of the scope to SMEs and private investments and opposing mandatory standardized disclosure. However, it welcomed the proposal by the Commission in 2021 on the Corporate Sustainability Reporting Directive (CSRD), emphasizing that it should be aligned and compatible with legislation already in place, such as the SFDR and that it should follow the materiality and proportionality principles.
Transparency: Invest Europe has published a complete and accurate account of its positions and engagement activities on specific sustainable finance policies. It is also fully transparent about its members, including which companies and individuals hold key positions in the executive and on key committees.