Response to the consultation paper of the European Supervisory Authorities (ESAs) on the disclosure regulation
GBIC welcomes the proposed measures to enhance sustainability in finance. However, GBIC expresses criticism of the Level II proposals of the European Supervisory Authorities regarding the disclosure of information concerning sustainability factors in investment services and products. Due to the high complexity and the planned level of detail of the disclosure obligations, the requirements create high bureaucratic burdens that would hinder growth of a still comparatively small market for sustainable investments while making it more difficult for small and medium-sized banks to enter the market. It is not to be expected that the information provided will actually contribute to better information for consumers. In any case, there is a lack of consistency of the disclosure obligations, other regulatory frameworks (i. e. EU taxonomy, Level II requirements for MiFID II) and the availability of ESG data. That is why GBIC advocates a postponement of the application date of the disclosure regulation to January 1, 2022.