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The European Commission’s Sustainable Finance Action Plan and Other International Initiatives

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Sustainable Finance in Europe

Part of the book series: EBI Studies in Banking and Capital Markets Law ((ESBCML))

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Abstract

Since the publication of the European Commission’s 2018 Action Plan and—similarly—the 1st edition of this book, significant progress has been made on the execution of the Action Plan and putting into effect the actions identified in the Plan. The actions respond to five broad strategies that can be defined as ‘public incentives’, ‘standardisation’, ‘disclosure’, ‘corporate governance’ and ‘financial regulation’. The first strategy consists of fostering investments through financial and technical support for sustainable infrastructure and other projects. The second strategy includes the establishment of an EU taxonomy of sustainable activities which should help shifting capital flows towards them. It also includes the setting of standards and labels for green financial products, which should enhance the trust in the market of these products and ease investors’ access to them. The third strategy covers both corporate disclosure and third party information and assessments. The fourth strategy combines sustainable corporate governance with attenuating short-termism in capital markets and assumes that boards should develop their own sustainability strategies and act in the company’s long-term interest. The fifth strategy implies at least three types of regulatory reform. Sectoral requirements have been amended in the sense that investment firms and insurance distributors should consider sustainability issues when offering financial advice. Second, fiduciary duties of asset managers and institutional investors have been clarified so as to include ESG factors in the investment processes. Third, ESG is being incorporated in prudential requirements of financial institutions so that they channel their investments towards a more sustainable economy, while reducing the risks deriving from unsustainable economic development. Building on the fundamentals of the 2018 Sustainable Finance Action Plan, the European Commission has adopted a renewed sustainable finance strategy in 2021. The European Commission observes that, since 2018, its understanding of what is needed to meet the sustainability goals has evolved, and the global context has changed. Accordingly, the European Commission is taking significant steps in the further development of a European Sustainable Finance framework, building on the foundations of the 2018 Action Plan. These foundations are formed by three building blocks: (1) the EU taxonomy of sustainable activities, (2) a disclosure framework for non-financial and financial companies and (3) investment tools, including benchmarks, standards and labels. The renewed sustainable finance strategy identifies four areas in which additional action is required: (1) financing the transition of the real economy towards sustainability; (2) develo** a more inclusive sustainable finance framework; (3) improving the financial sector’s resilience and contribution to sustainability (under a double materiality perspective); and (4) fostering global ambition. Within these four areas, the European Commission has formulated six actions, divided into a number of specific action points and proposals, to achieve the sustainability objectives. The related actions are discussed in the second part of this chapter. These actions generally require regulation and/or supervision often at EU level, but private incentives and cultural developments towards an environmentally sustainable economic system will also be important in furthering the success of the Action Plan and the renewed sustainable finance strategy.

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Notes

  1. 1.

    Communication from Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, The European Green Deal, COM/2019/640 final, 11 December 2019.

  2. 2.

    Resolution 70/1 adopted by the United Nations General Assembly on 25 September 2015, https://www.un.org/en/development/desa/population/migration/generalassembly/docs/globalcompact/A_RES_70_1_E.pdf.

  3. 3.

    https://sdgs.un.org/goals.

  4. 4.

    4 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, The European Green Deal, COM/2019/640 final, 11 December 2019, paragraph 2.2.1.

  5. 5.

    Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, Strategy for Financing the Transition to a Sustainable Economy, https://eur-lex.europa.eu/resource.html?uri=cellar:9f5e7e95-df06-11eb-895a-01aa75ed71a1.0001.02/DOC_1&format=PDF.

  6. 6.

    Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, A sustainable finance framework that works on the ground, 13 June 2023, COM(2023) 317 final, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023DC0317.

  7. 7.

    Compromising the technical screening criteria for the remaining four environmental objectives set out in the Taxonomy Regulation, in addition to the initial two objectives, for which the technical screening criteria were already finalised in an earlier stage. See further, paragraph 2.3.1 of this chapter. An overview of the implementing and delegated acts adopted under the EU Taxonomy Regulation can be found at the website of the European Commission: https://finance.ec.europe.eu/document/download/083f92ce-1f3d-464a-88a3-5079dee8eef5_en?filename=taxonomy-regulation-level-2-measures-full_en.pdf.

  8. 8.

    Proposal for a regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, (COM(2023) 314 final). A political agreement on this proposal was reached on 5 February 2024. See further, paragraph 2.3.5.1 of this chapter.

  9. 9.

    EU High-Level Expert Group on Sustainable Finance, Financing a Sustainable European Economy: https://ec.europa.eu/info/sites/info/files/180131-sustainable-finance-final-report_en.pdf.

  10. 10.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 2.

  11. 11.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 3.

  12. 12.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), pp. 4–11.

  13. 13.

    European Commission, consultation on the renewed sustainable finance strategy, 8 April 2020, https://finance.ec.europa.eu/system/files/2020-04/2020-sustainable-finance-strategy-consultation-document_en.pdf.

  14. 14.

    European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, Strategy for Financing the Transition to a Sustainable Economy, 6 July 2021, COM(2021) 390 final.

  15. 15.

    Sustainable Europe Investment Plan.

  16. 16.

    European Commission, The European Green Deal Investment Plan and Just Transition Mechanism explained, 14 January 2020, https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_24.

  17. 17.

    Communication from Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions, The European Green Deal, COM/2019/640 final, 11 December 2019, paragraph 2.2.1.

  18. 18.

    Proposal for a Regulation of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment, COM(2018) 353 final (24 May 2018), p. 1 (Explanatory Memorandum).

  19. 19.

    Transforming our World: The 2030 Agenda for Sustainable Development (UN 2015) available at https://sustainabledevelopment.un.org/post2015/transformingourworld.

  20. 20.

    COM(2016) 739 final.

  21. 21.

    CO EUR 17, CONCL. 5.

  22. 22.

    Proposal for a Regulation of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment, COM(2018) 353 final (24 May 2018), recital (2).

  23. 23.

    Council Decision (EU) 2016/1841 of 5 October 2016 on the conclusion, on behalf of the European Union, of the Paris Agreement adopted under the United Nations Framework Convention on Climate Change (OJ L 282, 19.10.2016, p. 4).

  24. 24.

    Proposal for a Regulation of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment, COM(2018) 353 final (24 May 2018), recital (3).

  25. 25.

    Established as part of the United Nations Conference on the Human Environment in Stockholm in 1972.

  26. 26.

    More or less in parallel, the UNEP joined forces in 1995 with leading insurance and reinsurance companies, forming the UNEP Insurance Industry Initiative, working closely together with the UNEP Financial Institutions Initiative, and subsequently, in 2000, merging into the UNEP Finance Initiative.

  27. 27.

    Created as a spin-off of from the UNEP FI and the UN Global Compact.

  28. 28.

    Which have become part of the insurance industry criteria of the Dow Jones Sustainability Indices and FTSE4Good and (as of July 2015) representing 83 organisations, including insurers representing approximately 20% of the world premium volume and USD 14 trillion in assets under management.

  29. 29.

    Representing approximately 200 banks across the world.

  30. 30.

    https://www.unepfi.org/about/.

  31. 31.

    https://tnfd.global/recommendations-of-the-tnfd/.

  32. 32.

    The Sustainable Insurance Forum (SIF) is a leadership group of insurance supervisors and regulators working together to strengthen their understanding of and responses to sustainability issues facing the insurance sector. As of October 2020, the SIF has 30 jurisdictions as its members.

  33. 33.

    www.iaisweb.org.

  34. 34.

    Recent work includes the comparison of taxonomies and transition finance.

  35. 35.

    https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance/international-platform-sustainable-finance_nl.

  36. 36.

    As of 13 June 2023, the NGFS consists of 127 members and 20 observers: https://www.ngfs.net/en/about-us/membership. International or regional financial institutions and international or regional standard setting, regulatory, supervisory and central bank bodies which have demonstrated a proven commitment in sustainable finance are eligible to be NGFS observers.

  37. 37.

    https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/.

  38. 38.

    At European level, the CSRD provides that the delegated acts under the CSRD (i.e. the sustainability reporting standards) should take account, to the greatest extent possible, of the work of global standard-setting initiatives for sustainability reporting, and existing standards and frameworks for natural capital accounting and for greenhouse gas accounting, responsible business conduct, corporate social responsibility, and sustainability development.

  39. 39.

    The Taxonomy Regulation is discussed in more detail in Chapter 13 of this book by C.V. Gortsos and D. Kyriazis.

  40. 40.

    This platform, which is discussed further below in this paragraph in some more detail, is the European Union’s Platform on Sustainable Finance, established on the basis of article 20 of the Taxonomy Regulation, https://finance.ec.europa.eu/sustainable-finance/overview-sustainable-finance/platform-sustainable-finance_en.

  41. 41.

    To this end, pursuant to article 8 of the Taxonomy Regulation, any undertaking which is subject to an obligation to publish non-financial information pursuant to Article 19a or Article 29a of Directive 2013/34/EU shall include in its non-financial statement or consolidated non-financial statement information on how and to what extent the undertaking’s activities are associated with economic activities that qualify as environmentally sustainable under Articles 3 and 9 of the Taxonomy Regulation.

  42. 42.

    The Sustainable Finance Disclosure Regulation is discussed in more detail in Chapter 14 of this book by D. Busch.

  43. 43.

    In fact, the SFDR has been amended by article 25 of the Taxonomy Regulation. In addition, articles 5 to 8 of the Taxonomy Regulation reference directly to the categorisation of financial products in the SFDR.

  44. 44.

    Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the annual financial statements, consolidated financial statements and related reports of certain types of undertakings, amending Directive 2006/43/EC of the European Parliament and of the Council and repealing Council Directives 78/660/EEC and 83/349/EEC, OJ EU 29 June 2013, L 182/19.

  45. 45.

    Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014 amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups, OJ EU November 15, 2014, L 330/1.

  46. 46.

    Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards corporate sustainability reporting, OJ EU 16 December 2022, L 322/15.

  47. 47.

    Initially only leading to a disclosure requirement under article 8 of the Taxonomy Regulation for ‘eligibility’, to be extended to ‘alignment’ as from 1 January 2023 (non-financial undertakings) and 1 January 2024 (financial undertakings), see article 10 of the Taxonomy Regulation Delegated Act, (EU) 2021/2178.

  48. 48.

    This Complementary Delegated Act corresponds to Action 1 (c) of the renewed EU Sustainable Finance Strategy.

  49. 49.

    According to the European Commission, nuclear energy represents a low-carbon energy source. On the other hand, evidence is less conclusive on the criterion of DNSH (do no significant harm). For that reason, the European Commission obtained specific expert advice. On the basis of that advice, the European Commission has concluded that compliance with the safety standards and waste management requirements under the regulatory framework in EU Member States ensures a high level of protection for the environment and for people. On natural gas, the European Commission views that natural gas will continue to play an important role in terms of consumption and generation until 2030, after which it expects to decline to 2050. Throughout the transition of our energy system, the function of natural gas-fired electricity generation will change and will increasingly be a facilitator for the spread of renewable electricity and stable supply. According to the European Commission, the Complementary Delegated Act recognises the specific role of natural gas-related activities in the transition. The technical screening criteria should ensure that all relevant requirements of the Taxonomy Regulation are complied with. By identifying the role of natural gas in the transition, the Delegated Act also recognises the different situations in our Member States, while contributing to a sustainable transition: See further: Questions and Answers on the EU Taxonomy Complementary Climate Delegated Act covering certain nuclear and gas activities, Brussels, 2 February 2022, https://ec.europa.eu/commission/presscorner/detail/en/qanda_22_712.

  50. 50.

    In addition to the first two objectives (climate change mitigation and climate change adaptation) these are (1) the sustainable use and protection of water and marine resources, (2) the transition to a circular economy, (3) pollution prevention and control and (4) the protection and restoration of biodiversity and ecosystems.

  51. 51.

    To this effect, the European Commission adopted the Environmental Delegated Act (under the Taxonomy Regulation) on 27 June 2023, which was published in the Official Journal of the European Union on 22 November 2023:: Commission Delegated Regulation (EU) 2023/2486 of 27.6.2023 amending Delegated Regulation (EU) 2021/2139 establishing additional technical screening criteria for determining the conditions under which certain economic activities qualify as contributing substantially to climate change mitigation or climate change adaptation and for determining whether those activities cause no significant harm to any of the other environmental objectives, C (2023) 3850 final., OJ EU L 22.12 2023. According to the renewed sustainable finance strategy (action 1(d)), this was originally planned for Q2 2022.

  52. 52.

    European Commission, Platform on sustainable finance: https://finance.ec.europa.eu/sustainable-finance/overview-sustainable-finance/platform-sustainable-finance_en#what.

  53. 53.

    https://commission.europa.eu/document/d07e1f1e-3a1f-4d55-add4-a130f26b33e3_en.

  54. 54.

    https://finance.ec.europa.eu/system/files/2022-03/220329-sustainable-finance-platform-finance-report-environmental-transition-taxonomy_en.pdf.

  55. 55.

    https://finance.ec.europa.eu/system/files/2022-04/220330-sustainable-finance-platform-finance-report-remaining-environmental-objectives-taxonomy_en.pdf.

  56. 56.

    EU Platform on Sustainable Finance, Final report on minimum safeguards, October 2022, https://finance.ec.europa.eu/system/files/2022-10/221011-sustainable-finance-platform-finance-report-minimum-safeguards_en.pdf.

  57. 57.

    In particular (1) the OECD Guidelines for Multinational Enterprises, (2) the UN Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions set out in the Declaration of the International Labour Organisation on fundamental principles and rights at work and (3) the International Bill of Human Rights.

  58. 58.

    For a detailed overview, we refer to Chapter 12 of this book by M. Driessen.

  59. 59.

    G20 Green Finance Study Group, G20 Green Finance Synthesis Report, 2016: European Commission Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), pp. 4–5.

  60. 60.

    European Commission Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 5.

  61. 61.

    These are funds integrating environmental, social and governance factors in their investment decision-making process. European Commission Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), footnote 20 on p. 5.

  62. 62.

    Regulation (EU) 2023/2631 of the European Parliament and of the Council of 22 November 2023 on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and for sustainability-linked bonds, OJ EU L 23.11.2023.

  63. 63.

    See: https://data.consilium.europa.eu/doc/document/PE-27-2023-INIT/en/pdf.

  64. 64.

    Regulation (EU) 2017/1129 of the European Parliament and of the Council of 14 June 2017 on the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market, and repealing Directive 2003/71/EC, OJ 2017 L 168.

  65. 65.

    “Sustainability-linked bond” means a bond whose issuer provides investors with a commitment or any form of pre-contractual claim that the bond proceeds are allocated to economic activities that contribute to an environmental objective (art. 2(6) EU Green Bond Regulation).

  66. 66.

    https://susproc.jrc.ec.europa.eu/product-bureau/product-groups/432/hom.

  67. 67.

    Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU Ecolabel (OJ 2010 L 27).

  68. 68.

    JRC Technical Reports, Development of EU Ecolabel criteria for Retail Financial Products, (Draft) Technical Report 4.0: Draft proposal for the product scope and criteria, March 2021. This fourth technical report provides an update to the set of criteria proposals contained in the Third Technical Report. Available at: https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2021-03/2021.03.05%20-%20EUEL%20financial%20products%20-%20Technical%20Report%204%20FINAL.pdf.

  69. 69.

    European Commission, Strategy for Financing the Transition to a Sustainable Economy, COM(2021) 390 final, https://finance.ec.europa.eu/publications/strategy-financing-transition-sustainable-economy_en.

  70. 70.

    https://finance.ec.europa.eu/sustainable-finance/disclosures/eu-labels-benchmarks-climate-esg-and-benchmarks-esg-disclosures_en.

  71. 71.

    Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2017/1129, (EU) No 596/2014 and (EU) No 600/2014 to make public capital markets in the Union more attractive for companies and to facilitate access to capital for small and medium-sized enterprises, COM(2022), 762 final. The proposal is part of the so-called ‘Listing Package’, https://finance.ec.europe.eu/publications/capital-markets-union-clearing-insolvency-and-listing-package_en.

  72. 72.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 5.

  73. 73.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 5 and footnote 22.

  74. 74.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 6.

  75. 75.

    Sustainable Europe Investment Plan.

  76. 76.

    European Commission, The European Green Deal Investment Plan and Just Transition Mechanism explained, 14 January 2020, https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_24.

  77. 77.

    Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the InvestEU Programme and amending Regulation (EU) 2015/1017, OJ 2021 L 107 (26 March 2021), p. 30.

  78. 78.

    https://investeu.europa.eu/investeu-programme/investeu-fund_en.

  79. 79.

    Commission Staff Working Document, Strategy for Financing the Transition to a Sustainable Economy, SWD (2021) 180 final, p. 8.

  80. 80.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 7.

  81. 81.

    Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance.

  82. 82.

    Regulation (EU) 2019/2089 of the European Parliament and of the Council of 27 November 2019 amending Regulation (EU) 2016/1011 as regards EU Climate Transition Benchmarks, EU Paris-aligned Benchmarks and sustainability-related disclosures for benchmarks (PbEU 2019, 317).

  83. 83.

    Commission Delegated Regulation (EU) 2020/1816 of 17 July 2020 supplementing Regulation (EU) 2016/2011 as regards the explanation in the benchmark statement of how environmental, social and governance factors are reflected in each benchmark provided and published (PbEU 2020 L 406). Commission Delegated Regulation (EU) 2020/1817 of 17 July 2020 supplementing Regulation (EU) 2016/2011 as regards the minimum content of the explanation on how environmental, social and governance factors are reflected in the benchmark methodology (PbEU 2020 L 406). Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020 supplementing Regulation (EU) 2016/2011 as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned benchmarks (PbEU 2020 L 406).

  84. 84.

    https://finance.ec.europa.eu/sustainable-finance/disclosures/eu-labels-benchmarks-climate-esg-and-benchmarks-esg-disclosures_en.

  85. 85.

    See also par. 2.3.2.

  86. 86.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 7.

  87. 87.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), pp. 7–8.

  88. 88.

    ESMA, Final report and Guidelines on Disclosure Requirements Applicable to Credit Ratings, 18 July 2019. ESMA33-9–320 https://www.esma.europa.eu/sites/default/files/library/esma33-9-320_final_report_guidelines_on_disclosure_requirements_applicable_to_credit_rating_agencies.pdf.

  89. 89.

    European Commission, Proposal for a Regulation of the European Parliament and of the Council on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, COM(2023) 314. The provisional political agreement is subject to formal approval by the Council and the Parliament. The regulation will start applying 18 months after its entry into force. See: https://www.consilium.europa.eu/en/press/press-releases/2024/02/05/environmental-social-and-governance-esg-ratings-council-and-parliament-reach-agreement/#:~:text=ESG%ratings%20provide%20an%20opinion,on%20society%20and%20the%20environment.

  90. 90.

    European Commission, Strategy for Financing the Transition to a Sustainable Economy, COM(2021) 390 final, https://finance.ec.europa.eu/publications/strategy-financing-transition-sustainable-economy_en. See also par. 2.1 and 2.4.

  91. 91.

    European Commission, Sustainable Finance Package, https://finance.ec.europa.eu/publications/sustainable-finance-package-2023_en.

  92. 92.

    European Commission, Directorate-General for Financial Stability, Financial Services and Capital Markets Union, ‘Study on sustainability-related ratings, data and research’, Publications Office of the European Union, 2021. See: https://data.europa.eu/doi/10.2874/14850.

  93. 93.

    The legislative proposal does not intend to harmonise the methodologies used for the creating of ESG rating, but to increase their transparency. ESG rating providers will remain in full control of the methodologies they use and will continue to be independent in their choice, to ensure that a variety of approaches are available in the ESG ratings market.

  94. 94.

    Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector, OJ 2019 L 317.

  95. 95.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 8.

  96. 96.

    www.fiduciaryduty21.org. The project was launched in January 2016 by the PRI and UNEP FI, with the support of the Generation Foundation.

  97. 97.

    This project has three components: (i) work to develop and publish a global statement on investors’ obligations and duties; (ii) publishing roadmaps on the policy changes required to achieve full ESG integration in investment practices across eight countries; (iii) extending research into investor’s obligations and duties to six Asian markets.

  98. 98.

    Fiduciary Duty in the 21st Century, Final Report, https://www.unpri.org/download?ac=9792.

  99. 99.

    The report stated that there are three main reasons why the fiduciary duties of loyalty and prudence require the incorporation of ESG issues: (1) ESG incorporation is an investment norm; (2) ESG issues are financially material; and (3) Policy and regulatory frameworks are changing to require ESG incorporation.

  100. 100.

    Fiduciary Duty in the 21st Century, Final Report, p. 8, https://www.unpri.org/download?ac=9792.

  101. 101.

    Fiduciary Duty in the 21st Century, Final Report, p. 2, https://www.unpri.org/download?ac=9792.

  102. 102.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 8.

  103. 103.

    E.g. the prudent person principle under Solvency II for insurance and reinsurance undertakings.

  104. 104.

    Commission Delegated Regulation (EU) 2021/1253 of 21 April 2021, amending Delegated Regulation (EU) 2017/565 as regards the integration of sustainability factors, risks and preferences into certain organisational requirements and operating conditions for investment firms (MiFID II Delegated Regulation); Commission Delegated Directive 2021/1269 of 21 April 2021 amending Delegated Directive (EU) 2017/593 as regards the integration of sustainability factors into the product governance obligations (MIFID II Delegated Directive); Commission Delegated Regulation (EU) 2021/1256 of 21 April 2021 amending Delegated Regulation (EU) 2015/35 as regards the integration of sustainability risks in the governance of insurance and reinsurance undertakings (Solvency II Delegated Regulation); Commission Delegated Regulation (EU) 2021/1257 of 21 April 2021 amending Delegated Regulations (EU) 2017/2358 and (EU) 2017/2359 as regards the integration of sustainability factors, risks and preferences into the product oversight and governance requirements for insurance undertakings and insurance distributors and into the rules on conduct of business and investment advice for insurance-based investment products (IDD); Commission Delegated Regulation (EU) 2021/1255 of 21 April 2021 amending Delegated Regulation (EU) No 231/2013 as regards the sustainability risks and sustainability factors to be taken into account by Alternative Investment Fund Managers (AIFMD); Commission Delegated Directive (EU) 2021/1270 of 21 April 2021 amending Directive 2010/43/EU as regards the sustainability risks and sustainability factors to be taken into account for Undertakings for Collective Investment in Transferable Securities (UCITS).

  105. 105.

    EIOPA, Technical advice for the review of the IORP II Directive, 28 September 2023, EIOPA-BoS-23/341,

    https://www.eiopa.europa.eu/system/files/2023-09/EIOPA-BoS-23-341-Advice_IORPII_review.pdf.

  106. 106.

    EIOPA, Technical advice for the review of the IORP II Directive, 28 September 2023, EIOPA-BoS-23/341,

    https://www.eiopa.europa.eu/system/files/2023-09/EIOPA-BoS-23-341-Advice_IORPII_review.pdf, Chapter 6.

  107. 107.

    About the SFDR, see further Chapter 14 of this book by D. Busch.

  108. 108.

    Article 1 of the SFDR.

  109. 109.

    Feedback Statement, Public Consultation on Institutional Investors’ and Asset Managers’. Duties regarding Sustainability page 23, https://commission.europa.eu/system/files/2018-05/2017-investors-duties-sustainability-feedback-statement_en.pdf, 24 May 2018.

  110. 110.

    The NFRD requires large (i.e. public interest entities that either have a balance sheet total that exceeds €20,000,000 or a turnover that exceeds €40,000,000) ‘Public Interest Entities’ with more than 500 employees to include non-financial statements as part of their annual reporting.

  111. 111.

    Letter of the European Commission to the three European Supervisory Authorities, dated 20 October 2020, application of Regulation (EU) 2019/2088 on the sustainability-related disclosures in the financial services sector, https://www.esma.europa.eu/sites/default/files/library/eba_bs_2020_633_letter_to_the_esas_on_sfdr.pdf.

  112. 112.

    On prudential requirements for banks and sustainability, see further E.PM. Joosen, Chapter 9. On prudential requirements for insurance undertakings and sustainability, see further A.J.A.D. van den Hurk, Chapter 10.

  113. 113.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 9.

  114. 114.

    In this context, we refer in particular to S. Grünewald, Climate Change as a Systemic Risk in Finance: Are Macroprudential Authorities up to the Task? and S. Lovisolo, Climate Change as a Threat to Financial Stability: Can Solutions to This Problem Accelerate the Transition to a Low Carbon Economy? A critical review of Policy and Market-Based Approaches, both chapters n D. Busch, G. Ferrarini, S. Grünewald (ed.) Sustainable Finance in Europe, Corporate Governance, Financial Stability and Financial Markets, EBI Studies in Banking in Capital Markets Law, Palgrave Macmillan, 2021 (2nd edition forthcoming); S. Grünewald, Macroprudential policies and climate risks. European Banking Institute Working Paper Series 2023–no. 133, 2023, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4327142.

  115. 115.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 9.

  116. 116.

    ESMA’s technical advice to the European Commission on integrating sustainability risks and factors in MiFID II, Final Report (ESMA 35–43-1737), 30 April 2019, https://www.esma.europa.eu/sites/default/files/library/esma35-43-1737_final_report_on_integrating_sustainability_risks_and_factors_in_the_mifid_ii.pdf and EIOPA’s Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and IDD (EIOPA-BoS-19/172), 30 April 2019, https://register.eiopa.europa.eu/Publications/EIOPA-BoS-19-172_Final_Report_Technical_advice_for_the_integration_of_sustainability_risks_and_factors.pdf.

  117. 117.

    EIOPA Opinion on Sustainability within Solvency II EIOPA-BoS-19/241, 30 September 2019, https://register.eiopa.europa.eu/Publications/Opinions/2019-09-30%20OpinionSustainabilityWithinSolvencyII.pdf.

  118. 118.

    It should be noted that the prudent person principle has both quantitative and qualitative characteristics and therefore is both a pillar 1 and pillar 2 topic.

  119. 119.

    EIOPA-BoS-19/241.

  120. 120.

    https://register.eiopa.europa.eu/Publications/Requests%20for%20advice/signed_letter_28_08_18.pdf.

  121. 121.

    https://www.eiopa.europa.eu/consultations/consultation-draft-opinion-supervision-use-climate-change-risk-scenarios-orsa_en.

  122. 122.

    https://www.eiopa.europa.eu/system/files/2021-07/methodological_paper-potential-inclusion-of-climate-change-in-the-natcat-standard-formula.pdf.

  123. 123.

    EIOPA, Opinion on the supervision of the use of climate change risk scenarios in ORSA, 19 April 2021, EIOPA-BoS-21/127.

  124. 124.

    EIOPA, Application guidance on running climate change materiality assessment using climate change scenarios in the ORSA, 2 August 2022, EIOPA-BoS-22/329.

  125. 125.

    EIOPA sensitivity analysis of climate-change related transition risks, 15 December 2020, https://www.eiopa.europa.eu/system/files/2020-12/sensitivity-analysis-climate-change-transition-risks.pdf.

  126. 126.

    EIOPA, European insurers’ exposure to physical climate change risk, potential implications for non-life business, 20 May 2022, EIOPA-BoS-22/278; EIOPA and ECB, Staff Paper on Policy options to reduce the climate insurance protection gap, 24 April 2023.

  127. 127.

    EIOPA, Discussion paper on the Prudential Treatment of Sustainability Risks, 29 November 2022, EIOPA-BoS-22/527.

  128. 128.

    EIOPA, Methodological paper on the potential inclusion of climate change in the Nat Cat standard formula, 29 June 2021, EIOPA-BoS-21/253 and EIOPA, Consultation Paper on the prudential treatment of sustainability risks, 13 December 2023, EIOPA-BoS-23–460. As of 2020, initially in pilot form, EIOPA also publishes a yearly dashboard on the insurance protection gap on natural catastrophes, https://www.eiopa.europa.eu/tools-and-data/dashboard-insurance-protection-gap-natural-catastrophes_en. On 3 April, 2024, following its earlier preparatory work, EIOPA has launched a public consultation on reassessing natural catastrophe risks in the Solvency II standard formula for the calculation of insurers' Solvency Capital Requirement (SCR): https://www.eiopa.europe.eu/eiopa-consults-natural-catastrophe-risk-reassessments-standard-formula-2024-04-03_en.

  129. 129.

    IAIS, May 2021, Application Paper on the supervision of climate-related risks in the insurance sector, https://www.iaisweb.org/uploads/2022/01/210525-Application-Paper-on-the-Supervision-of-Climate-related-Risks-in-the-Insurance-Sector.pdf.

  130. 130.

    Commission Proposal for the review of the Solvency II Directive of 22 September, 2021. Paragraph 91 introduces the new Article 304a with two mandates to EIOPA as regards sustainability risks. EIOPA is mandated to explore by 2023 a dedicated prudential treatment of exposures related to assets or activities associated substantially with environmental and/or social objectives and to review regularly the scope and the calibration of parameters of the standard formula pertaining to natural catastrophe risk.

  131. 131.

    Council of the European Union 2022, article 304(3).

  132. 132.

    EIOPA Staff Paper on nature-related risks and impacts for insurance, 27 March, 2023, EIOPA-23-247, https://www.eiopa.europa.eu/system/files/2023-03/EIOPA%20Staff%20paper%20-%20Nature-related%20risks%20and%20impacts%20for%20insurance.pdf.

  133. 133.

    European Parliament briefing on the proposal amending the Solvency II Directive, https://www.europarl.europa.eu/RegData/etudes/BRIE/2023/739314/EPRS_BRI(2023)739314_EN.pdf.

  134. 134.

    Article 41 of the Solvency II Directive.

  135. 135.

    Arthur van den Hurk, the role of prudential regulation and supervision of insurers in sustainable finance, Chapter 10.

  136. 136.

    EIOPA, Report on Non-life Underwriting and Pricing in Light of Climate Change, 1 July 2021, EIOPA-BoS-21/259, https://www.eiopa.europa.eu/system/files/2021-07/report-impact-underwriting.pdf. EIOPA, 2 December 2020, discussion paper on a methodology for the potential inclusion of climate change in the Solvency II standard formula when calculating natural catastrophe underwriting risk: https://www.eiopa.europa.eu/consultations/discussion-paper-methodology-potential-inclusion-climate-change-nat-cat-standard-formula_en.

  137. 137.

    EIOPA, Report on Non-life Underwriting and Pricing in Light of Climate Change, 1 July 2021, EIOPA-BoS-21/259, https://www.eiopa.europa.eu/system/files/2021-07/report-impact-underwriting.pdf, p. 18.

  138. 138.

    European Banking Authority, Roadmap on Sustainable Finance, 13 December 2022, EBA/REP/2022/30, https://www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2022/ESG%20roadmap/1045378/EBA%20Roadmap%20on%20Sustainable%20Finance.pdf.

  139. 139.

    See next paragraph.

  140. 140.

    Article 98 (8) CRD V.

  141. 141.

    EBA Report on management and supervision of ESG risks for credit institutions and investment firms, EBA/REP/2021/18, 23 June 2021.

  142. 142.

    Directive 2019/878/EU.

  143. 143.

    In particular Sects. 2.2 and 2.3 of that report. The proposed amendments relate to article 4(1) of the CRR (sub 52d–52i).

  144. 144.

    Press release EBA, 23 June 2011, EBA publishes its Report on management and supervision of ESG risks for credit institutions and investment firms, https://www.eba.europa.eu/eba-publishes-its-report-management-and-supervision-esg-risks-credit-institutions-and-investment.

  145. 145.

    Article 434a CRR 2.

  146. 146.

    Including article 449a CRR 2 on ESG risks.

  147. 147.

    Article 501c of CRR 2.

  148. 148.

    A political agreement was reached on the implementation of the Basel III reforms on June 27, 2023. A text on the provisional agreement was published on December 6, 2023

  149. 149.

    EBA Report on management and supervision of ESG risks for credit institutions and investment firms, 23 June 2021, EBA/REP/201/18.

  150. 150.

    See article 73, 74 and 76 of the CRD VI proposal in particular.

  151. 151.

    Article 87a CRD.

  152. 152.

    EBA/CP/2024/02. Following the political agreement and the subsequent technical meetings of the trilogue negotiators, The consultation paper was based by EBA on the text of the Provisional agreement published on the Council’s website on 6 December 2023. https://www.consilium.europa.eu/en/press/press-releases/2023/06/27/banking-sector-provisional-agreement-reached-on-the-implementation-of-basel-iii-reforms.

  153. 153.

    Article 23 EBA Regulation (Identification and measurement of systemic risk).

  154. 154.

    Article 76 CRD to monitor and address the risks arising in the short, medium and long term from the misalignment of the business model and strategy of the institutions with the relevant EU policy objectives or broader ESG transition trends.

  155. 155.

    Article 76 CRD.

  156. 156.

    Art. 91 CRD VI, see also the ECB guide to fit and proper assessments, December 2021, pp. 41–42.

  157. 157.

    Art. 430 (1) sub h CRR proposal.

  158. 158.

    Article 449a CRR.

  159. 159.

    Article 449a and 434a CRR proposal.

  160. 160.

    In addition to a commitment to explore the feasibility of the inclusion of risks associated with climate and other environmental factors in institutions’ risk management policies.

  161. 161.

    EBA/REP/2023/34. Based on the revised text of article 501c, pursuant to CRR III, the report should have been published by 28 June 2023. Initially, in accordance with CRR II, the report should have been submitted by 28 June 2025.

  162. 162.

    Article 35 of the IFD.

  163. 163.

    Article 32a of the IFR.

  164. 164.

    Page 9, EBA Report on the role of environmental and social risks in the prudential framework of credit institutions and investment firms. The agreed text on CRR III does contain a lower risk weight on the exposure of institutions to the European Emissions Trading System (40%). https://www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2023/1062711/Report%20on%20the%20role%20of%20environmental%20and%20social%20risks%20in%20the%20prudential%20framework.pdf.

  165. 165.

    EBA press-release 12 October 2023, The EBA recommends enhancements to the Pillar 1 framework to capture environmental and social risks, https://www.eba.europa.eu/eba-recommends-enhancements-pillar-1-framework-capture-environmental-and-social-risks.

  166. 166.

    Article 98 of CRD VI.

  167. 167.

    European Central Bank, November 2020, Guide on climate-related and environmental risks Supervisory expectations relating to risk management and disclosure: https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.202011finalguideonclimate-relatedandenvironmentalrisks~58213f6564.en.pdf.

  168. 168.

    European Central Bank, final results, thematic review of climate-related and environmental risks, 2 November 2022. https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.221102_presentation_slides~76d2334552.en.pdf.

  169. 169.

    European Central Bank, July 2022, Climate Risk Stress Test Report, Paragraph 6.1, https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.climate_stress_test_report.20220708~2e3cc0999f.en.pdf.

  170. 170.

    European Supervisory Authorities’ Joint Committee Report on Risks and Vulnerabilities in the EU Financial System, Autumn 2019, 26 August 2019, https://www.eiopa.europa.eu/publications/risks-and-vulnerabilities-eu-financial-system_en.

  171. 171.

    European Supervisory Authorities’ Joint Committee Report on Risks and Vulnerabilities in the EU Financial System, Autumn 2019, 26 August 2019, https://www.eiopa.europa.eu/publications/risks-and-vulnerabilities-eu-financial-system_en.

  172. 172.

    European Supervisory Authorities’ Joint Committee Report on risks and vulnerabilities in the EU Financial System, March 2023, JC 2023/07.

  173. 173.

    Joint Committee, 2023 Work Programme of the Joint Committee of the European Supervisory Authorities, 5 September 2002, JC 2022, 28, paragraph 5.

  174. 174.

    Joint Committee, 2024 Work Programme of the Joint Committee of the European Supervisory Authorities, 13 September 2023, JC 2023, 25, paragraph 5.

  175. 175.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), pp. 9–10.

  176. 176.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 10.

  177. 177.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 10. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1577-Fitness-check-on-public-reporting-by-companies_en.

  178. 178.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 10.

  179. 179.

    Directive (EU) 2022/2464, OJ EU 16 December 2022, L 322/15.

  180. 180.

    Initially, for financial year 2024, the CSRD will apply to undertakings that are already subject to the NFRD, in the following years to be supplemented with large undertakings not yet subject to the NFRD (as from financial year 2025), small and medium-sized undertakings and certain other undertakings (financial year 2026) and to third country undertakings as from financial year 2028.

  181. 181.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 10.

  182. 182.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 10.

  183. 183.

    https://www.efrag.org/Assets/Download?assetUrl=%2Fsites%2Fwebpublishing%2FSiteAssets%2FJean-Paul%20Gauzès%20-%20Ad%20Personam%20Mandate%20-%20Final%20Report.pdf.

  184. 184.

    In the form of delegated acts.

  185. 185.

    Article 1(17) of the CSRD, amending article 49 of (EU) 2013/34/EU. These conditions relate to due process, public oversight, transparency, sufficient expertise and balanced representation, public funding to ensure independence, based on a work programme on which the European Commission has been consulted. In addition, the advice should be accompanied by a cost–benefit analysis, explanation on the legal basis in art. 29b(5) of the Accounting Directive. Lastly, participation in EFRAG’s work on technical level should be based on expertise on sustainability reporting and not on a financial contribution.

  186. 186.

    Between 29 April 2022 and 8 August 2022.

  187. 187.

    ESRS 1, General requirements and ESRS 2, General Disclosures.

  188. 188.

    ESRS E1, Climate Change, ESRS E2, Pollution, ESRS E3, Water and Marine Resources, ESRS E4 Biodiversity and Ecosystems, ESRS E5, Resource use and circular economy, ESRS S1, Own Work Force, ESRS S2, Workers in the value chain, ESRS S3, Affected communities, ESRS S4, Consumers and end-users, and ESRS G1, Business conduct.

  189. 189.

    https://www.efrag.org/Activities/2205170712504435/ESRS-Sector-Standards. On 17 October 2023, the European Commission published its 2024 Work Programme and announced, in the context of the CSRD, among others, the extension of the period in which sector-specific standards should be developed. https://commission.europa.eu/strategy-documents/commission-work-programme_en.

  190. 190.

    Published in the Official Journal of the EU on 16 December 2022, Directive (EU) 2022/2464 OJ EU L 322/15.

  191. 191.

    Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards, OJ EU L 22.12 2023.

  192. 192.

    Article 1 (8) of the CSRD, article 29(b) paragraph 5 of Directive 2013/34/EU.

  193. 193.

    EFRAG, Interoperability between ESRS and ISSB standards, EFRAG assessment at this stage and map** table, EFRAG SRB meeting, 23 August 2023, paper 04–02: https://www.efrag.org/Assets/Download?assetUrl=%2Fsites%2Fwebpublishing%2FSiteAssets%2F22%2520Appendix%2520V%2520Comparison%2520of%2520IFRS%2520and%2520ESRS%25201%2520and%25202.pdf.

  194. 194.

    https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/.

  195. 195.

    https://www.europarl.europa.eu/doceo/document/TA-8-2016-0381_EN.html.

  196. 196.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 10. See also Follow up to the European Parliament resolution on International Financial Reporting Standards: IFRS 9, response to paragraph 8, pp. 3–4: SP (2017) 67, 29 March 2017, https://oeil.secure.europarl.europa.eu/oeil/popups/ficheprocedure.do?lang=en&reference=2016/2898(RSP).

  197. 197.

    https://www.efrag.org/Activities/2010051123028442/Non-financial-reporting-standards.

  198. 198.

    https://www.efrag.org/Assets/Download?assetUrl=/sites/webpublishing/Project%20Documents/1806281004094308/Technical%20advice%20letter%20Equity%2030%20January%202020.pdf.

  199. 199.

    See further Chapter 4 of this book by G. Ferrarini and Chapter 5 by A. Pacces.

  200. 200.

    See further Chapter 7 of this book by M. Siri and S. Zhu.

  201. 201.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), p. 11.

  202. 202.

    ESMA, Report on undue short-term pressure on corporations, https://www.esma.europa.eu/press-news/esma-news/esma-proposes-strengthened-rules-address-undue-short-termism-in-securities: EBA Report on undue short-term pressure from the financial sector on corporations, https://eba.europa.eu/sites/default/documents/files/document_library/Final%20EBA%20report%20on%20undue%20short-term%20pressures%20from%20the%20financial%20sector%20v2_0.pdf; EIOPA: Potential Undue Short-term pressure from financial markets on corporates: Investigation on European insurance and occupational pension sectors Search for evidence, year-end 2018, https://www.eiopa.europa.eu/publications/potential-undue-short-term-pressure-financial-markets_en#files.

  203. 203.

    European Commission, Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, COM(2022) 71 final.

  204. 204.

    The scope of the CSDDD proposal of the European Commission included ‘regulated financial undertakings’, but in the compromise text of CSDDD each EU Member State has discretion to extend the scope of the obligations of the CSDDD to financial undertakings, https://data.consilium.europa.eu/doc/document/ST-15024-2022-REV-1/en/pdf. According to the political agreement, reached on 14 December 2023, financial undertakings will only have to apply the CSDDD in relation to their own operations and upstream supply chains. Financial undertakings will also have to adopt a climate change transition plan ensuring their business model complies with limiting global warming to 1.5°C. There will be a review clause for a possible future expansion of the scope for financial undertakings.

  205. 205.

    European Commission, Strategy for Financing the Transition to a Sustainable Economy, COM(2021) 390 final, https://finance.ec.europa.eu/publications/strategy-financing-transition-sustainable-economy_en. See also Sect. 2.1.

  206. 206.

    As per the date of finalising the text of this chapter, the EBA has not yet published its advice to the European Commission.

  207. 207.

    EU Platform on Sustainable Finance, Final Report on Social taxonomy, February 2022, https://finance.ec.europa.eu/system/files/2022-08/220228-sustainable-finance-platform-finance-report-social-taxonomy_en.pdf.

  208. 208.

    European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, Strategy for Financing the Transition to a Sustainable Economy, 6 July 2021, COM(2021) 390 final.

  209. 209.

    Disclosure requirements under the Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy Regulation, and the sustainability reporting requirements under the Non-Financial Reporting Directive (NFRD), complemented by the Corporate Sustainability Reporting Directive (CSRD).

  210. 210.

    European Commission, Call for input to ESMA, EIOPA and the EBA Regarding Greenwashing Monitoring and Supervision, 16 May 2022, https://www.eba.europa.eu/sites/default/documents/files/document_library/About%20Us/Missions%20and%20tasks/Call%20for%20Advice/2022/CfA%20on%20greenwashing/1036481/Cover%20Letter_ESA%20request%20on%20greenwashing%20monitoring%20and%20supervision.pdf.

  211. 211.

    EBA, Progress Report on Greenwashing Monitoring and Supervision, 31 May 2023, https://www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2023/1055934/EBA%20progress%20report%20on%20greewnwashing.pdf. ESMA, Progress Report on Greenwashing, 31 May 2023, https://www.esma.europa.eu/sites/default/files/2023-06/ESMA30-1668416927-2498_Progress_Report_ESMA_response_to_COM_RfI_on_greenwashing_risks.pdf. EIOPA, Advice to the European Commission on Greenwashing—Progress Report, 1 June 2023, https://www.eiopa.europa.eu/system/files/2023-06/EIOPA%20Progress%20Report%20on%20Greenwashing.pdf.

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    https://joint-research-centre.ec.europa.eu/scientific-activities-z/sustainable-finance/sustainable-finance-research-forum_en.

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    https://finance.ec.europa.eu/sustainable-finance/international-platform-sustainable-finance_en.

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    International Platform on Sustainable Finance, Transition Finance Report, November 2022, https://finance.ec.europa.eu/system/files/2022-11/221109-international-platform-sustainable-report-transition-finance_en.pdf.

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  1. Financial Law Centre (FLC), Radboud University Nijmegen, Nijmegen, The Netherlands

    Arthur van den Hurk

  2. International Centre of Financial Law & Governance (ICFG), Erasmus University Rotterdam, Rotterdam, The Netherlands

    Ingrid van der Klooster

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  1. Financial Law Centre (FLC), Radboud University Nijmegen, Nijmegen, The Netherlands

    Danny Busch

  2. Department of Law, University of Genoa, Genoa, Italy

    Guido Ferrarini

  3. Financial Law Centre (FLC), Radboud University Nijmegen, Nijmegen, The Netherlands

    Seraina Grünewald

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van den Hurk, A., van der Klooster, I. (2024). The European Commission’s Sustainable Finance Action Plan and Other International Initiatives. In: Busch, D., Ferrarini, G., Grünewald, S. (eds) Sustainable Finance in Europe. EBI Studies in Banking and Capital Markets Law. Palgrave Macmillan, Cham. https://doi.org/10.1007/978-3-031-53696-0_2

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