We fully support the ambitions of the new CMU Action Plan. Properly executed, it has the potential to boost the fortunes of Europe’s pensioners and savers by creating opportunities for them to share in the upside of Europe’s economic recovery and to create more efficient and better integrated European capital markets, which is key to finance European innovation as well as the transition towards a more sustainable and digital economy.

The European investment management industry is helping savers achieve their financial goals and build up retirement savings. Investment management is a vital part of the European economy, providing funding for companies and infrastructure projects and contributing to economic growth and job creation across all Member States.

As the voice of European asset management industry, EFAMA strongly welcomes the development of 
the EU Taxonomy and its technical screening criteria. We see the Taxonomy as a critical tool to 
unleashing the potential of sustainable finance in Europe by assisting issuers, project promoters, 
companies, investors, and other financial market participants in identifying truly sustainable economic 
activities. We wish to put forward recommendations that aim to improve the usability and integrity of this 
framework.

The fund and asset management industry is a highly regulated industry operating under significant and specific legal, regulatory, transfer pricing and tax frameworks. 

Pillar 1: Investment funds are structured as tax neutral investment pooling vehicles as a matter of
public policy.

Pillar 2: The role that investment funds play in providing investors with a diversified portfolio and global market access is essential.