EUU, Alm.del - 2023-24 - Bilag 214: Orienteringsnotat, høringssvar og ministerbrev om dansk høringssvar vedr. Kommissionens offentlige høring om revision af SFDR (disclosureforordningen)

Europaudvalget 2023-24
EUU Alm.del Bilag 214
Offentligt

Mairead McGuinness

Commissioner of Financial Stability, Financial Services and

Capital Markets Union

European Commission

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Response from the Danish Government to the Commission’s targeted

consultation on the EU’s Sustainable Finance Disclosure Regulation

Dear Commissioner McGuinness,

Thank you for the opportunity to respond to the Commission’s public consultation

on the EU’s Sustainable Finance Disclosure Regulation (SFDR).

Denmark supports an ambitious approach to sustainable finance – a cornerstone

in the green transition and in supporting the EU’s commitment to the climate goals

of the Paris Agreement, the Montreal/Kunming Agreement, the United Nation’s

Sustainable Development Goals as well as other relevant environmental Conven-

tions. A part of this ambition is to continue to ensure the EU’s position as a global

front-runner and standard setter in sustainable finance.

Since its adoption, SFDR has played a crucial role in sustainable finance and has

increased the comparability and disclosures of financial products. SFDR has pro-

vided a framework and structure for enabling consumers and investors to make

informed investment decisions. However, regulatory and market developments

call for a revision of the regulation to make it fully fit for purpose and to support

capital flows to the green transition and sustainable development.

In the revision of SFDR, it is important to ensure that the sustainability-related

disclosures strengthen investor protection. The SFDR should support the preven-

tion of greenwashing, and it should allow investors to better compare the sustain-

ability profile of investment products. This will support investors' confidence in

the financial sector and provide investors with financial products that match the

investor’s needs and preferences.

Consistency across regulation and balance between benefits and burdens

It is important to ensure consistency across regulation. This should be a particular

focus in the SFDR review, as the sustainable finance legislation is quickly grow-

ing and a consistent framework is needed to support growth of green and sustain-

able capital flows. In this regard, ensuring consistency between the Corporate

Sustainability Reporting Directive (CSRD), the Taxonomy and SFDR is of par-

ticular importance. It is important to find the right balance between investor pro-

tection and the need for credible data, on the one hand, and to avoid disclosure

MINISTRY OF INDUSTRY, BUSI-

NESS AND FINANCIAL AFFAIRS

Slotsholmsgade 10-12

DK-1216 Copenhagen K

Tlf.

Fax

+45 33 92 33 50

+45 33 12 37 78

CVR-nr. 10 09 24 85

EAN nr. 5798000026001

[email protected]

www.em.dk

EUU, Alm.del - 2023-24 - Bilag 214: Orienteringsnotat, høringssvar og ministerbrev om dansk høringssvar vedr. Kommissionens offentlige høring om revision af SFDR (disclosureforordningen)

requirements, which do not create sufficiently added value for investors and con-

sumers, on the other hand. Further, clarity in the regulatory framework should be

set in basic acts (level 1), establishing central concepts and requirements at the

political level, and not in delegated acts (level 2) without proper framing and

guidance.

In this new and complex legal area, we urge the Commission to be mindful of

burdens associated with new regulation. It is in our view very important that ben-

efits and burdens of new regulation are balanced. Hence, we call on the Commis-

sion to conduct thorough impact assessments, including of the burdens. The cur-

rent principles and transparency requirements should remain.

Creating new financial product categories

Denmark agrees on the need for creating financial product categories for sustain-

ability with clearly defined minimum criteria. This will make it easier for inves-

tors to compare and trust the financial products, and it will ensure that financial

products making sustainability-related claims do in fact contribute to a sustainable

economy. When drafting the product categories it is of utmost importance that

small private investors are protected and not mislead by the information provided.

In our view, it is essential to build proper financial product categories based on

the existing concepts of SFDR such as “sustainable investments” and “principle

adverse impact indicators”. Moreover, we would suggest that the revision of

SFDR should include more specific requirement for Do No Significant Harm test,

transition finance and create a “social framework” to support a uniform applica-

tion of the regulation and to push ambitions and heighten the contributions from

the financial sector.

Transition finance as central aspect of sustainable finance

Finally, we wish to raise the importance of transition finance as a central aspect

of sustainable finance and a facilitating force towards investments in a sustainable

economy. In the revision of SFDR, we see a strong need to define both transition

investments and transition financial product categories. A clear distinction should

be made between those investments and financial products, which can be catego-

rised as already sustainable and those, which could support the green transition.

The transition should be credible and include milestones linked to global targets

– not only on climate, but also other environmental targets, including biodiversity

and potentially social goals.

We are at your disposal for any questions or comments that you might have, and

we look forward to a fruitful dialogue on these important issues.

Yours sincerely,

Morten Bødskov

Minister for Industry, Business,

and Financial Affairs

Magnus Heunicke

Minister for

Environment

Lars Aagaard

Minister for Climate,

Energy and Utilities