The Sustainability Disclosure Regulation

The Commission proposes to force financial market participants and financial advisors to disclose to what extent they take environmental, social and governance (ESG) factors into account when making investment decisions or providing financial advice. We analyse the Commission‘s proposal and present the negotiating positions of the Council and the European Parliament.


From the cep's perspective, financial market participants and financial advisors should not be obliged to inform investors about sustainability factors in their investment decisions and advisory processes. If investors are interested in sustainability factors, financial market participants and advisors have a self-interest in disclosing this information. Furthermore, there is no objective definition of sustainability. The integration of ESG considerations by institutions for occupational retirement provision (IORPs) in their investment decisions is a substantial change to the IORP-II-Directive and may, therefore, not be prescribed by the Commission in delegated acts, but only by the legislator.