Sustainable Finance Lobbying Overview: 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, particularly regarding pension funds.
Top-line Messaging on Sustainable Finance Policy: In 2022, PensionsEurope supported the objectives of the new EU Sustainable Finance Strategy in order to support the EU Green Deal and Europe’s transition to becoming a carbon-neutral continent by 2050. However, in feedback to the European Supervisory Authorities (ESAs) in 2023, PensionsEurope argued that "greenwashing" regulation should focus on parties "seeking unfair competitive advantage" instead of expanding legislative and supervisory powers and suggested that pension funds should be excluded given they are not ""market participants" that sell a "product.""
Position on Taxonomies: During 2018-2019, PensionsEurope was supportive of a stringent approach to the EU Taxonomy. In more recent comments, PensionsEurope stated opposition to an expansion of the EU Taxonomy to cover environmentally harmful activities in a 2020 response to the Commission, and in a 2021 press release on the EU’s Renewed Strategy on sustainable finance. In 2022, PensionsEurope stated support for “broadening the scope of the taxonomy to include more sectors in the green taxonomy”, including sectors that play a role in the transition, those that do not have a significant impact on environmental sustainability, as well as those with significant harm. However, it has specifically opposed a binary “green” and “brown” taxonomy.
Position on ESG standards and labels: In feedback to the Commission in 2020, PensionsEurope appeared to support a European level accreditation scheme for the EU Green Bond Standard but argued that the "narrow nature" of the taxonomy created a "limitation".
Position on regulated corporate ESG disclosure: In 2020, PensionsEurope advocated for an ambitious review of the Non-Financial Reporting Directive (NFRD) in feedback to the European Commission and in 2021 it welcomed the extension of scope in the newly relabelled Corporate Sustainability Reporting Directive (CSRD), and advocated for even more ambitious disclosure requirements. In response to the European Financial Reporting Advisory Group (EFRAG) in 2022, PensionsEurope broadly supported the European Sustainability Reporting Standards (ESRS), suggesting that materiality assessments may not be omitted without an explicit explanation or statement. However, it suggested exempting pension funds, asset managers and other financial market participants from reporting under CSRD given that "SFDR reporting requirements already provide stakeholders with sufficient information". In feedback to the Commission’s proposal on the ESRS in 2023, PensionsEurope argued against the approach to materiality proposed due to concerns around subjectivity, which implies support for higher ambition. It did suggest that pension funds should not be required to disclose what investee companies have deemed to be non-material. PensionsEurope has further advocated for international ESG reporting, supporting the Climate Exposure Draft proposed by the International Sustainability Standards Board (ISSB) in 2022.
Position on Integrating ESG into Investor Duties: PensionsEurope appears to have been activelyengaged on policy changes to incorporate ESG issues into fiduciary duty, with mostly negative positions. In September 2019, PensionsEurope argued for a delay to the implementation of the Sustainable Finance Disclosure Regulation (SFDR) and pushed for a delay again in April 2020. 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 comments to the review of the SFDR in 2023, it urged the European Supervisory Authorities (ESAs) to minimize changes until sufficient time to meet the existing standards has passed. 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. In a 2022 position paper, it further cautioned against a requirement to survey all members regarding sustainability preferences and asked for flexibility for pension fund boards to decide whether to incorporate ESG considerations. In input to the European Insurance and Occupational Pensions Authority (EIOPA) in 2022, it also opposed additions to reporting for institutions for occupational retirement provision (IORPs) including ESG data, arguing that it would increase burden and costs.
Transparency: PensionsEurope has published a complete and accurate account of its positions and engagement activities on specific sustainable finance-related policies. It is also transparent about general and board membership, but has not disclosed about membership of committees and working groups.