Response to ESMA consultation on draft advice on Taxonomy Regulation Article 8

We welcome the opportunity to provide input on ESMA’s draft advice to the European Commission under Article 8 of the Taxonomy Regulation. A clearly defined taxonomy, whereby agreement on what constitutes environmentally sustainable assets is found, is a necessary starting point for other actions, such as standards and labels. This will also assist high quality and comparable financial disclosures.

FESE generally agrees with ESMA’s proposal regarding the definition of turnover, CapEx and OpEx. The draft advice includes several references to the EU Green Bond Standards. However, as there is currently no legal certainty on this proposal it seems premature to link the analysis, advice and methodology under Article 8 of the Taxonomy Regulation to it. FESE would also advise to further consider the current lack of data (at least for the first years).

We believe it is important that the regulatory frameworks are consistent and not overly complicated for market participants to comply with. It is therefore key to ensure alignment in the upcoming review of the NFRD and the possible creation of non-financial reporting standards.