EU Commission Action Plan on Financing Sustainable Growth: Summary
About one month ago the EU Commission published the Action Plan on Financing Sustainable Growth, a dense 20 page document that "sets out an EU strategy for sustainable finance" building upon the Final Report of the High-Level Expert Group on Sustainable Finance (you can find my thoughts on the HLEG Report here). More interestingly, the Action Plan boldly states: "Following the decision of the United States to withdraw from the 2015 Paris Agreement, there is a growing need for global leadership in the move towards sustainable development. Europe is well-placed to step into the role of global leader."
I took my time to analyze the document and see to what extent there is substance to that claim. Here are my 7 highlights. Spoiler alert: I think EU is bloody serious about sustainable finance.
No. 1: The Action Plan is connected to other key initiatives the Commission is working on, specifically the multi-stakeholder platform on the SDG implementation and the EU Capital Markets Union project.
No. 2: Mainstreaming sustainability in risk management. If in the past 2 years there were only few visionaries talking about the link between non-financial dimensions and risk identification, assessment, mitigation, in 2018 this is the new standard. In other terms, if you're not thinking in this perspective, you're lagging behind. More importantly, this perspective broadens the definition of materiality. So far, companies defined material issues looking at the impacts they have on stakeholders, but the Commission is demanding to assess the impact that environmental and social factors have on the business activities – calculating the exposure to environmental and social risks. This resonates a lot with the scenario analysis recommended by the TCFD – even if the Commission indications are broader than climate change only.
No. 3: Unified EU classification system – or EU Green Taxonomy, including Ecolabeling for financial products. The Action Plan proposes a "step-by-step approach, starting with a taxonomy on climate change mitigation and adaptation activities and some environmental activities." I can see why the Commission wants to start from climate change – there's plenty of work, including the TCFD, already available on the subject. Still, I am concerned that the Commission could get stuck for a long time on the taxonomy for climate change, missing the opportunity of defining a taxonomy for areas that are less explored (hence more in need for a taxonomy!); by following this "step-by-step" approach there is the risk that the taxonomy isolates the issues, not considering the interdependencies among them (e.g. how climate change is linked to migration and violation of human rights for example).
No. 4: Amendment of MiFID II. The potential amendment of the Directive in Q2 2018 would have a significant impact for the industry and the mainstreaming of ESG. Insurance distributors and investment firms would be required to "ask about their clients' preferences (such as environmental, social and governance factors) and take them into account [...] in the product selection process and suitability assessment." I wonder how many providers would be prepared for that.
No. 5: More on risk management and sustainability (I told you that this is important!) Firstly, integrating sustainability into credit rankings (the Commission may amend the Credit Rating Agency Regulation in that sense); secondly, explicitly indicating sustainability as part of the fiduciary duty of institutional investors and asset managers; thirdly, Exploring the calibration of capital requirements for banks, by amending the Capital Requirement Regulation and Directive introducing a supporting factor for sustainable assets, as defined by the EU taxonomy. This supporting factor could be adopted to "better reflect the risk of sustainable assets." The supporting factor is a concrete measure to establish the relationship between risk and sustainability in practical terms, provided that it really factors in measures of risk – otherwise it will be just another subsidy to the green economy (and nobody really needs that).
No. 6: Amending accounting rules and the non-financial reporting directive. I know, I know – we're still aligning to the non-financial reporting directive and they're already amending it. By Q2 2019, the Commission will revise the guidelines to align them to the TCFD recommendations. In a way, this means that the TCFD will be mandatory in the EU. Moreover, the Commission is exploring ways to propose an amendment to IFRS 9, concerning the accounting treatment for long-term investment portfolios of equity and equity-type instruments. In particular, the Commission is concerned that the current fair value measurement treatment is not conducive to "long-term investment."
No. 7: Fight short-termism. In line with the point above, the Commission is taking an hard stance against short termism by considering the introduction of new disclosure requirements for corporate boards ("require corporate boards to develop and disclose a sustainability strategy, including appropriate due diligence throughout the supply chain, and measurable sustainability targets"). Also, the Commission will ask the European Securities Markets Authority to collect information on "undue short-termism in capital markets, including portfolio turnover and equity holding periods by asset managers, and whether there are any practices in capital markets that generate undue short-term pressure in the real economy."
I'll conclude with the nice visualization of the actions the Commission included at the end of the Action Plan:
Author: Donato Calace / Director of Innovation at Datamaran