EFAMA responds to the opportunity to provide feedback to the Article 8 Taxonomy Regulation (EU) 2020/852 (‘taxonomy’) draft delegated act, which the European Commission published for consultation on 7 May. We highlight that the provisions on investee companies in this delegated act will serve as the primary source of input for asset managers´ own disclosures on taxonomy compliance at both product and entity levels.

EFAMA welcomes the Commission´s proposal for a transitional period introduced in the Article 11 of this delegated act, as it will address numerous practical implementation challenges identified in our consultation responses to ESMA´s technical advice under Article 8 of the taxonomy, the European Commissions´ consultation on the taxonomy climate delegated act and the ESA´s consultation on Taxonomy-related product disclosures in SFDR. Nonetheless, to ensure implementation feasibility and consistency within the EU´s sustainable finance regime, we would like to make the following recommendations:

1. Alignment of the proposed transitional period with taxonomy-related product disclosures in the Sustainable Finance Disclosures Regulation 2019/2088 (SFDR) and ESG updates to MiFID II and IDD delegated acts

2. Potential confusion caused by quantitative taxonomy eligibility disclosure requirements during the transitional period
 

3. Need for consistent taxonomy alignment methodologies at entity and product level

4. Taxonomy alignment of firms not in the scope of NFRD
 

5. Screening of all assets under management against the taxonomy at the entity and SFDR Article 6 product level should be optional