We've compared the different positions of the European Commission, Council of the EU and the European Parliament on the review of the SFDR. Read below our recommendations for this trilogue.
Trilogue negotiations on the SFDR review are due to start on 22 October and envisioned to finish by the end of 2026.
Parliament's text is the strongest of the three on most issues. Its main weakness is ESG Basics: retail investors receive a single indicator on fossil fuel exposure and little other information from which to assess performance, which risks perpetuating the catch-all character of Article 8 under SFDR 1.0.
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Below, we set out our three priorities for the trilogue and the specific solutions we recommend to address them.
Parliament requires a single indicator for ESG Basics, exposure to the fossil fuel sector, and this must be retained. We ask that Parliament's own Transition wording be applied to Article 8, so that ESG Basics products report GHG emissions and fossil fuel exposure, together with one further indicator selected for relevance. This corresponds to the three indicators required by Council for Transition and Sustainable.
Council limits the effect of safe harbour to points (a) to (c) of the first subparagraph, so that PAI disclosure under point (d) continues to apply to products using the bypass. Parliament deems all conditions met. We ask the co-legislators to support the Council's scope.
The Commission proposal contains no opt-out, and we ask the co-legislators to maintain this position. If an opt-out is retained, Parliament's version is preferable to Council's, because it requires that no retail investor has access to the fund and requires a pre-contractual statement of non-categorisation.
Speech by Filip Gregor at the public hearing on Reporting Obligations, held by the European Parliament's Committee on Legal Affairs on 13th May 2025
Whilst the European Parliament and the Council are in the midst of analysing and debating the Omnibus Simplification Package, we suggest our key changes for the co-legislators to implement to ensure that the CSRD is respected.
Following the European Commission’s announcement of its Omnibus Simplification Package at the end of February, both the Council and the European Parliament must now reach their own positions on the proposals, before the trilogue negotiations between all three bodies commence again.