On July 6, 2020, ISDA and AFME submitted their joint response to the European Commission’s consultation on the Delegated Acts (DAs) under MiFID II meant to introduce changes to suitability requirements and integrate sustainability risks across product governance, operating conditions, risk management and organisational requirements. In the response, the Associations recommend an appropriately staggered timetable for implementing the DAs due to the significant challenges that the proposed sequencing could pose for firms. The associations also note that availability of relevant and reliable environment, social and governance (ESG) data from issuers remains a significant issue, and will continue to remain so for some time, which will impede the process of identifying to what extent a product meets a client’s sustainability preferences. The Associations are still reviewing the definition of sustainability preferences in the DAs, particularly with respect to how Article 8 and 9 of the Disclosure Regulation should be applied to financial instruments, and they plan to engage further with the Commission on this issue.