InfluenceMap Score
for Sustainable Finance Policy Engagement
Performance Band
Organisation Score
Brussels, Belgium
Official Web Site:

PensionsEurope has communicated high-level support for many sustainable finance policies in Europe, but has cautioned against a prescriptive approach to regulatory intervention in this area.

PensionsEurope has supported the role of the financial sector in meeting the EU's climate goals and appears to support reform to the financial sector to make it more sustainable.

PensionsEurope has stated broad support for the taxonomy via its social media channels and, in a 2018 position paper, supported its extension to cover social issues but argued against the exclusion of “entire sectors from the investment universe”. In feedback to the European Commission’s Technical Expert Group (TEG) in 2019, PensionsEurope appeared to support a stringent approach to classification that would make a clear distinction between activities that are already sustainable and those that contribute to sustainability more indirectly. However, in the same set of feedback, PensionsEurope did oppose the expansion of the taxonomy to cover environmentally harmful activities and reiterated this position in consultation to the Commission in 2020. In a press release in 2021 on the EU’s Renewed Strategy on sustainable finance, PensionsEurope again opposed the expansion of the taxonomy to include environmentally harmful activities. This position appeared to change in 2022, as PensionsEurope stated support for a "general taxonomy" that would include transitioning, as well as environmentally harmful activities. It did, however, suggest that the green taxonomy should be expanded to cover more sectors.

In feedback to the High-Level Group on Sustainable Finance (HLEG) in 2017, PensionsEurope appeared to advocate in favour of EU standards and labels that built upon or harmonised existing standards. In feedback to the TEG on the EU Green Bond Standard in 2018, PensionsEurope cautioned against a regulatory framework for external verification, suggesting that the effectiveness of a voluntary accreditation committee should be assessed first. However, in feedback to the Commission in 2020, PensionsEurope appeared to support a European level accreditation scheme but argued that the "narrow nature" of the taxonomy created a "limitation".

In 2019 PensionsEurope secretary general Matti Leppälä stated high-level support for the review of the Non-Financial Reporting Directive (NFRD) to improve “access to reliable and comparable non-financial data” and in 2020 PensionsEurope advocated for an ambitious review of the NFRD in feedback to the European Commission. Similarly, in 2021 PensionsEurope welcomed the extension of scope in the newly relabelled Corporate Sustainability Reporting Directive (CSRD), and advocated for even more ambitious disclosure requirements.

PensionsEurope appears to have been particularly engaged on policy changes to incorporate ESG issues into fiduciary duty. In 2018, PensionsEurope opposed prescriptive measures to incorporate ESG issues into the 'prudent person rule' in IORP II and also advocated against regulatory requirements to engage with beneficiaries on ESG issues. In September 2019, PensionsEurope argued for a delay to the implementation of the sustainability disclosures regulation and pushed for a delay again in April 2020, citing disruption caused by the COVID-19 pandemic. In technical feedback on the same regulation, PensionsEurope argued the proposed level of investor ESG disclosure was inappropriate for pension funds and would add a high burden of compliance. In feedback to the Commission on the Renewed Sustainable Finance Strategy in 2020, PensionsEurope again appeared to oppose further action on fiduciary duty, including on engaging with pension fund members' ESG preferences.

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