The Investment Association

InfluenceMap Score
for Sustainable Finance Policy Engagement
Performance Band
Organization Score

London, United Kingdom
Official Web Site:

Sustainable Finance Lobbying Overview: The Investment Association (IA) has communicated high-level support for sustainable finance policy in the EU and UK. The IA appears to have fairly high engagement on EU and UK sustainable finance policy, with mixed positions.

Top-line Messaging on Sustainable Finance Policy: The IA has strongly supported the UK’s net-zero by 2050 goal and advocated for investment strategies guided by the need to achieve zero-carbon economies by 2050. In written evidence to the UK Parliament in 2022, it further advocated for the Financial Conduct Authority (FCA) to contribute to the Climate Change Act 2008, and stated support for sustainable finance regulation. During 2022, in feedback to the UK Government, it did caution against incentives to only invest in low carbon sectors or regions and in comments to the HM Treasury, it questioned whether financial services regulation is the best "mechanism in which to include such wider economic and industrial policies" and highlighted that it is "important to preserve the principles of investor choice and the ability of fiduciaries to act in their clients’ best interests in accordance with their investment objectives" regulations.

Position on regulated corporate ESG disclosure: The IA has advocated for increased ambition on companies’ reporting on climate-related risks in a letter to the G7 leaders in 2021, and supported efforts by the IFRS Foundation consultation on sustainability reporting although it cautioned against implementing the double materiality approach used in the EU in 2022. It also supported TCFD implementation for standard listed companies and listed issuers in response to the FCA in 2020-2021. However, it has been less supportive in the implementation of the TCFD for asset managers, life insurers and FCA-regulated pension providers, cautioning against the mismatch in disclosures obligations through the investment chain and suggesting an "as far as you are able" approach for certain metrics. It also suggested the same approach to DWP in 2021 on disclosure by occupational pension schemes. During 2022, it has offered broad support for regulated corporate ESG disclosure, including data and methodologies of scope 3 emissions in response to the Update to the Green Finance Strategy in the UK, as well as Taskforce on Nature-related Financial Disclosures (TNFD)-aligned disclosures.

Position on Taxonomies: The IA has been cautious in its support for a taxonomy, both in the EU and UK. The IA opposed the expansion of the EU taxonomy to cover environmentally harmful activities in 2020. In comments to the UK House of Commons Treasury Committee in 2020, the IA stated concerns around the usability of a UK taxonomy, particularly around narrowing the sustainable investment definition. However, in its Climate Change position updated in 2022, it did support the ambition of the UK to be a “Net Zero-aligned Financial Centre” and develop a UK Green Taxonomy.

Position on ESG standards and labels: In comments to the FCA on ESG topics in capital markets in 2021, the IA opposed the need for a UK green bond standard and urged the FCA to encourage alignment with existing standards instead. In response to the FCA in 2022 on the Sustainability Disclosure Requirements (SDR), it highlighted that the labelling regime proposed should be more flexible and have less rigid categories. In response to the EU Commission’s Renewed Strategy consultation, the IA did not support proposed labels such as a label for investment funds. In similar comments to the European Securities and Markets Authority (ESMA) in 2022, the IA did not support setting quantitative thresholds prior to agreed eligibility criteria for sustainable investments.

Position on Integrating ESG into Investor Duties: The IA has generally supported integrating sustainability considerations into fiduciary duty, with some exceptions. In 2020, the IA advocated for a delay to implementation and suggested flexibility on principal adverse impacts disclosure in response to the European Supervisory Authorities on the Sustainable Finance Disclosure Regulation (SFDR). In response to the European Commission on its Renewed Sustainable Finance Strategy in 2020, the IA did not support the need to adapt rules on fiduciary duties or engage with pension fund members on ESG preferences, however, it did support the Commission’s proposal to explore ESG integration and reporting for pension providers. In the UK, the IA supported disclosures on the integration of ESG into investor duties as part of the FCA’s proposed Sustainability Disclosure Requirements (SDR) in 2022. However, also in 2022, it did state concerns about portfolio alignment metrics for pension schemes in response to the UK’s DWP.

Transparency: The IA has published a partial account of its positions and engagement activities on specific sustainable finance-related policies. However, it appears to exclude more than 3 material evidence of direct sustainable finance policy engagement identified by InfluenceMap's database, which appears to be published in its only-members area. The IA is transparent about its general and board memberships, however, it has not disclosed membership of committees and working groups.

Details of Organization Score