The European Fund and Asset Management Association (EFAMA) calls on the European Commission to reflect EFRAG´s recommendations for mandatory European Sustainability Reporting Standards in the upcoming NFRD review.

EFAMA supports the initiatives launched by IOSCO and other regulators (e.g. ESMA, FCA, SEC) to analyse and address the significant issues concerning market data in the secondary equity market.

As the European trade association representing numerous ETF issuers, EFAMA welcomes the opportunity of this questionnaire to submit a few high-level considerations to the attention of Committee 5 member supervisors. Our inputs are intended to accompany the more detailed submissions of the several European ETF issuers our association represents, in view of informing the Committee’s future work around a possible review of IOSCO’s 2013 Principles for the Regulation of Exchange Traded Funds.

Investors would benefit from an EU legal framework with due diligence guidelines and reporting requirements for companies in the real economy. This framework should be consistent with the reporting requirements in the revised NFRD and the disclosures in the Sustainability-Related Disclosures regulation (SFDR). At the same time, any framework for supply chain due diligence should not impose a competitive disadvantage for EU companies.