ISDA Position Paper on SFDR Review

On February 27, ISDA and the Association for Financial Markets in Europe (AFME) published a position paper on the European Commission’s (EC) proposed revisions to the Sustainable Finance Disclosure Regulation (SFDR 2.0). The paper welcomes the EC’s proposal as a strong starting point for negotiations, particularly the introduction of a product categorization framework and more streamlined disclosure requirements. These represent meaningful progress towards a more coherent regime that can effectively support capital flows to the sustainable transition.

From an ISDA perspective, the paper sets out several targeted recommendations to ensure the framework works effectively in practice – especially the need for coherence with related regulatory regimes, alignment of exclusion criteria with the Benchmarks Regulation (BMR) and clearer treatment of derivatives. The paper also calls for key frameworks governing the assessment of clients’ sustainability preferences to be updated swiftly, so they apply at the same time as the revised SFDR. The associations make the following key recommendations:

  • Ensure non-SFDR products with sustainability features can be offered to clients under the Markets in Financial Instruments Directive and the Packaged Retail and Insurance-based Investment Products regulation;
  • Retain the removal of portfolio management and advisory services from SFDR scope;
  • Uphold the simplified disclosure rules and provide immediate burden relief for entity-level disclosures;
  • Refine Article 7 criteria to facilitate the provision of transition finance; and
  • Integrate product categories with existing market standards and the investable universe for sustainable products.

Documents (1) for ISDA Position Paper on SFDR Review

Expanding the Universe of Eligible VM

ISDA conducted a series of interviews with buy- and sell-side firms to understand the drivers of a growing use of non-cash assets as variation margin (VM) for non-cleared over-the-counter (OTC) derivatives and the barriers that remain to expanding the use...

ISDA Response on Hedge Accounting Guidance

On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...