Consultations and letters

Region Month Consultation or letter PRI response
UK July

Treasury Select Committee | Decarbonisation of the UK economy and green finance

Following oral testimony before the Treasury Committee, the PRI has provided written evidence on the policies needed to achieve net zero emissions in the UK. The PRI’s recommendations include:

  • A more joined-up approach to developing climate policy across government
  • De-risking low-carbon investments by scaling up available finance in infrastructure and tech innovation funds
  • Provide a clear and stable direction regarding future carbon policy, such as clarity on carbon pricing beyond 2021 and a net zero national capital raising plan


See full submission

US July

House Financial Services Committee

The PRI commends the Subcommittee for calling this hearing to consider legislative approaches to require issuer disclosure of ESG data. Investors need access to consistent, comparable disclosure of material ESG data to make informed investment decisions.


See full response

US July

Securities and Exchange Commission

The PRI urges the Commission to promote long-term investing by ensuring investors have access to the information and tools necessary to incorporate material ESG factors into investment decisions. Short-termism in today’s markets leads to a series of negative externalities including market volatility and inefficiencies in capital allocation.


See full response

Hong Kong July

Hong Kong Stock Exchange | Consultation on the review of the ESG disclosure reporting guide and related rules

PRI recommends that material ESG information is published in the annual report and reported alongside financial indicators; ESG disclosure is placed under oversight by the board; the board sets quantified and dated ESG targets; that primary ESG metrics are required. In addition, we recommend industry-specific and forward looking disclosures aligned with the TCFD framework.


See full response

UK July

Financial Conduct Authority (FCA)

The PRI recommends that the FCA regulate Independent Governance Committees (IGCs) directly and require providers, rather than IGCs, to be the primary source of reporting for scheme beneficiaries.


See full letter

UK July

Financial Conduct Authority (FCA) | Consultation on extending the remit of Independent Governance Committees

The PRI welcomes extending the remit of IGCs to include material ESG factors, stewardship and integration of member views.


The PRI recommends that the FCA produce guidance to improve the quality of reporting for beneficiaries of contract-based schemes, and places a stronger imperative on providers to integrate member views.


See full response

UK April

Financial Conduct Authority (FCA) and Financial Reporting Council (FRC) | Discussion paper on Building a regulatory framework for effective stewardship

In light of regulatory changes proposed to encourage greater stewardship in the UK, the FCA and FRC jointly published a discussion paper on what further barriers to effective stewardship remain and how they might be overcome. The PRI recommends:


  • maintaining the proposed definition of stewardship, which reflects corresponding duties in the UK and beyond and emerging practices among some investors; and
  • featuring the outcomes achieved by stewardship activities more prominently in the proposed “key attributes”.

Proxy advisors and investors work together to address market actors’ concerns and strengthen their contribution to an effective stewardship culture.



See full response

Colombia April

Superintendencia Financiera de Colombia |  Comment on Technical Document of Good Practices

The PRI recommends that AFPs clarify that FCPs should incorporate ESG issues consistent with the time frame of the beneficiary, and that the ESG preferences of beneficiaries should be understood and incorporated. The PRI recommends that the Superintendencia Financiera de Colombia, and AFPs, refer to the PRI’s Limited Partners’ Responsible Investment Due Diligence Questionnaire (DDQ) as a starting point for engaging FCPs. 


See full response

UK April

Department for Work and Pensions (DWP) | Consultation on Investment Innovation and Future Consolidation

In February, the DWP opened a consultation to support greater pension fund investment in illiquid assets, and recommends that smaller direct contribution schemes consider consolidation. The PRI welcomes the consultation and recommends expanding the reporting scope for consolidation to include larger schemes.


See full response

UK March

Financial Reporting Council (FRC) | Consultation on a revised Stewardship Code

In January, the FRC proposed substantial revisions to the UK Stewardship Code, in its first update since 2012. The PRI strongly welcomes many of the proposed changes, particularly the explicit recognition of the importance of ESG considerations and the introduction of an annual reporting requirement. The PRI’s priority recommendations are:

  • The Code places a greater emphasis on the outcomes of stewardship activities.
  • The guidance should provide best practice examples of stewardship of other asset classes and be updated regularly.
  • Service providers’ responsibility to provide ESG-related services to clients should be explicitly recognised.
  • The FRC should avoid duplication between the reporting framework of the Stewardship Code and internationally-used frameworks.


See full response 

UK March 

Financial Conduct Authority (FCA) | Consultation on the implementation of the revised Shareholder Rights Directive

The PRI welcomes the regulatory baseline that the implemented Directive will introduce for disclosure of active ownership activities. The PRI recommends strengthening this baseline by requiring disclosure on a mandatory rather than comply or explain basis.


See full response

IOSCO March 

IOSCO consultation report on sustainable finance in emerging markets and the role of securities regulators 

This report and its recommendations will support securities regulators in promoting the development of responsible investment practices in  emerging markets. The PRI recommends that securities regulators introduce mandatory ESG disclosures, aligned with international standards and existing best practice, including explicit reference to TCFD implementation and reporting.


See full response

OECD March 

IOPS consultation on draft supervisory guidelines on the integration of ESG factors in the investment and risk management of pension funds

The draft guidelines will support pension fund supervisory authorities incorporate ESG requirements in investment regulations.
The PRI recommends that IOPS clarifies the definition of ESG integration in the guidelines and proposes that pension fund supervisors introduce regulations on ESG disclosures by pension funds and their asset managers.


See full response

EU March

European Securities and Markets Authority (ESMA) | Consultation on Disclosure Requirement applicable to Credit Ratings

The PRI welcomes the Guidelines on Disclosure Requirements Applicable to Credit Ratings as a significant step forward in transparency, by encouraging better signposting of how ESG factors may contribute to a credit rating opinion, rating outlook or related action.


The PRI recommends that ESMA amends its guidelines to better reflect that:


  • ESG Disclosure should stress how ESG factors contributed to the improvement or the deterioration of the credit quality of the entity or instrument rated
  • ESG factors are among many material elements considered to form a credit rating opinion
  • The disclosure requirements should apply to ratings opinions, rating outlooks and rating action


See full response

EU February 

European Securities and Markets Authority (ESMA) | Consultation on integrating sustainability risks and factors in MiFID II

In June 2017, the European Commission sent a request for technical advice to ESMA to supplement the initial package of legislative proposals and assist the Commission on potential amendments to the delegated acts under MiFID II.


The PRI supports many aspects of the proposed technical advice from ESMA. However, the PRI strongly recommends that the draft technical advice also provide clarity on investor duties, as set out in Article 21(1) of MiFID II.


See full response

EU

February

European Securities and Markets Authority (ESMA) | Consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD .

In June 2017, the European Commission sent a request for technical advice to ESMA to supplement the initial package of legislative proposals and assist the Commission on potential amendments to the delegated acts under UCITS Directive and AIFMD.


The PRI supports many aspects of the proposed technical advice. However, we strongly recommend that the draft technical advice also clarifies investor duties, as set out in Article 14(1) of the UCITS Directive and Article 12(1) of AIFMD.


See full response

France 

January 

Autorité des Marchés Financiers (AMF) |  Roadmap on Sustainable finance

The PRI strongly welcomes the AMF’s Roadmap on Sustainable finance. Our priority recommendations are:


  • The AMF, together with ACPR, should provide guidance on ESG integration and strengthen its oversight by publishing an annual overview of the market.
  • The AMF should articulate its activities supporting active ownership and increase transparency of (proxy) voting, as well as improve shareholder filing and accountability of the French stewardship code.


See full response in French

UK

January

FCA | Climate change and green finance

In October 2018, the FCA published a discussion paper on how the issues of climate change and green finance relate to the regulator’s objective of ensuring that markets work well.


The PRI’s priority recommendations are:

  • Financial regulators including the FCA, should issue official guidance that climate change is a material financial risk and thus required to be reported under existing UK law.
  • The FCA, together with other financial regulators, should integrate the TCFD recommendations throughout the existing corporate governance and stewardship reporting frameworks.
  • A comply-or-explain approach should be avoided.
  • The burden for issuers of these extensions to UK law can be reduced by implementing them over a two-year period and leveraging the FCA and PRA Climate Risk Forum.


See full response

EU

January

European Insurance and Occupational Pensions Authority (EIOPA) | Consultation Paper on Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and IDD

In June 2017, the European Commission sent a request for technical advice to EIOPA to supplement the initial package of legislative proposals and assist the Commission on potential amendments to the delegated acts under Solvency II and the Insurance Distributor Directive.


The PRI finds that ambiguity around investor duties has been a key barrier and therefore strongly welcomes the legal clarity proposed in EIOPA’s draft technical advice. The PRI recommends that the amendments be further aligned with the High-Level Expert Group recommendations on investor duties, governance and risk management.


See full response

Canada

January

Government of Canada | Interim report of the expert panel on sustainable finance

In April 2018, the Government of Canada announced the creation of the Expert Panel on Sustainable Finance, tasked with building on the work of similar initiatives around the world, including the Task Force on Climate-related Financial Disclosures, and developing recommendations on the types of finance and investment structures that will help build the low-carbon economy. The PRI’s priority recommendations are:


  • The Government of Canada should endorse the TCFD recommendations without delay. This should be part of a Canadian strategy on Sustainable Finance.
  • Department of Finance Canada should clarify that fiduciary duties require ESG integration.
  • Department of Finance Canada should ensure effective implementation, oversight and monitoring of responsible investment-related regulation.

See full response

Briefings

Region  Month Briefing  PRI briefing 

Global

September

Taking stock: Sustainable finance policy engagement and policy influence

Over the past five years, there has been a dramatic increase in the attention paid by financial policymakers to sustainability issues. Accompanying, and in some markets, leading this change, institutional investors have actively engaged with these policymakers on sustainability issues. The PRI monitors global sustainable finance policy. This white paper provides an overview of recent developments and presents five key findings.


See full briefing.

EU

August 

EU Regulation on sustainability-related disclosures in the financial services sector

This Regulation lays down transparency rules for financial market participants and financial advisers with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts. The briefing explains its implications.


See full briefing.

EU

August 

EU Regulation on EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks

This Regulation establishes a voluntary label for EU Climate Transition benchmarks and EU Paris-aligned benchmarks and lays down transparency rules for benchmark administrators with regard to the integration of ESG factors in their methodology. This briefing explains its implications.


See full briefing.

EU

June 

EU Sustainable Finance Taxonomy

The EU taxonomy is a tool to help investors understand whether an economic activity is environmentally sustainable. This briefing explains its purpose and relevance for investors.


See full briefing 

US

June 

US SEC New Conduct Rules

The US Securities and Exchange Commission finalized new rules for the conduct for investment professionals. The PRI believes all who provide investment advice owe their clients a fiduciary duty, which includes integration of material ESG factors.


See full briefing 

EU

April 

EU Regulation on a Pan-European Personal Pension Product 

The new Pan-European Personal Pension Product (PEPP) regulation sets out requirements for a new category of pension product. The regulation requires PEPP providers to consider risks related to ESG factors, as well as the potential long-term impact of investment decisions on ESG factors.


See full briefing 

Poland

January

Sustainable finance in Poland: The state of play and prospects for progress

This briefing maps the market structures that are hampering or supporting ESG integration in Poland. It will support further discussions about ongoing EU action as well as introduce the topic in a more structured and comprehensive manner to the public and financial sector representatives.


See full briefing

See consultation responses for 2018, 2017, 2016 and 2015.