Investment Company Institute (ICI)

InfluenceMap Score
Performance Band
Organisation Score
Washington DC, United States
Official Web Site:

The Investment Company Institute (ICI) is actively engaged on sustainable finance policy globally. Whilst it has shown some support for regulated corporate disclosure, ICI does not appear to support stringent regulatory intervention for the financial sector.

ICI has recognized the role of the financial sector in mitigating climate change, but it is unclear whether it is supporting systemic reforms. In a Joint Paper on Financing a US Transition to a Sustainable Low-Carbon Economy, ICI stated support for the financial sector’s role in delivering the goals of the Paris Agreement.

ICI has called for some government regulation on sustainable finance but has also emphasized the role that market-based solutions and real-economy regulation must play in achieving climate goals.

Aligned with the view that regulatory intervention should focus on the ‘real economy’, ICI has supported regulated corporate ESG disclosure, calling for collaboration between countries to achieve a global consensus on a disclosure framework. In a 2020 response to a European Commission consultation on the Non-Financial Reporting Directive (NFRD), ICI stated support for improving disclosure requirements for companies, emphasizing that investors cannot meet their own disclosure requirements without sufficient data from investee companies. However, in a 2021 response to the Commission’s review of the NFRD, ICI stated some concerns around the definition of double materiality and how it would apply to climate reporting. In a letter to the SEC in 2021, ICI called for mandatory disclosure of Scope 1 and 2 emissions by public companies, stating that ESG factors should be considered material. ICI has expressed support for the Biden Administration’s call for regulated corporate ESG disclosure and encouraged leadership on this issue in the global arena. After the SEC released its proposed climate disclosure rule in March 2022, ICI issued a press release in support of the proposal. ICI has outlined a more cautious position toward Scope 3 emissions disclosure requirements. In comments to the TCFD in 2021, ICI did not support requiring Absolute Scope 3 emissions in the Taskforce's proposed guidance on climate-related metrics.

In a 2021 response to the Singapore Green Finance Industry Taskforce’s consultation on a green taxonomy, ICI suggested that a taxonomy should not be too rigorous and cautioned against an overly narrow definition of “green” activities. In a response to the European Commission’s consultation on its renewed sustainable finance strategy, ICI did not support the Commission’s suggestions for new ESG standards and labels, warning that minimum standards would impede the ability of investors to choose from diverse sustainable investing strategies.

ICI has not supported integrating ESG factors into investor duties. In 2018 feedback on the European Commission’s proposed regulation on sustainability disclosures ICI emphasized that “dictating the ESG components of fiduciary duty would not be in the best interests of investors.” In response to the European Commission’s consultation on its renewed sustainable finance strategy in 2020 ICI did not support the Commission’s suggestions on further integrating sustainability into fiduciary duty. ICI has, in multiple instances, expressed its concern with the lack of data from corporate issuers which it says complicates ESG disclosure by asset managers. In 2020 comments to the Monetary Authority of Singapore and in 2021 comments to the Hong Kong Securities and Futures Commission ICI voiced support for a delayed, less prescriptive approach to regulating the way asset managers deal with climate risk. ICI supported the 2020 SEC shareholder proposal rule that raised the threshold for proxy proposals and limited shareholder engagement. Alternatively, ICI opposed the 2020 Department of Labor rules that sought to limit ESG investing and shareholder rights. However, in comments on the 2021 rollbacks of these rules, ICI asked the Department to remove and alter references to ESG considerations in rule language, taking issue with the “prescriptive” text.

ICI is transparent about its positions and advocacy efforts on sustainable finance policies, including letters sent to policymakers. ICI clearly discloses general and board membership.

Details of Organization Score