On September 10, ISDA, the Association for Financial Markets in Europe (AFME) and the European Fund and Asset Management Association (EFAMA) submitted a joint response to the European Commission’s (EC) call for evidence on reducing the administrative burden in environmental legislation. The joint response supports the EC’s objective of reducing unnecessary administrative burdens while ensuring environmental objectives remain intact. The associations believe that simplification efforts focused on the real economy are essential to improving the quality of information, avoiding overlapping rules and enabling effective sustainable finance.

In particular, the joint response highlights the need to:

• Ensure regulatory coherence with the existing sustainable finance framework (Sustainable Finance Disclosure Regulation, Taxonomy, Corporate Sustainability Reporting Directive and sectoral rules), avoiding duplication and double reporting.

• Maintain an exemption of financial products and services from the scope of the Green Claims Directive.

• Clarify that Deforestation Regulation due diligence obligations should apply to lead operators and traders rather than downstream financial institutions, which are already comprehensively regulated under EU sustainable finance rules.