CONCLUSION

The implementation of the SFDR would greatly benefit from a strong revision of its Disclosure Delegated Regulation, which sets out the specific disclosure requirements. It is crucial that the reported data provide concrete information on the actual environmental impact of investments and close the door to any greenwashing opportunities. We recommend that the ESAs revise the PAI indicators in this direction, avoiding indications of whether any policies to mitigate impacts are in place, but rather referring to established frameworksthatprescribestepstobuildaneffectivepolicyTransparencyoftheentirevaluechainisneededto accurately depict environmental impacts (such as on biodiversity and deforestation). This information is not currentlyavailablefromallnon-financialcompanies.TheEUCommissionmustthusensurethattheCSRDand the ESRS foreseen for its implementation provide an enabling framework for both financial and non-financial companies to understand which sustainability issues to assess and how. By weakening of the standards comparedtoEFRAG’sproposal,itwillbemoredifficultandburdensome forFIstounderstandwhycompanies report on certain sustainability topics and not others, in addition to the massive data gaps they face for their ownreportingobligations