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ESG Ratings: A European approach?
By Marta Morellato, EBF Financing Sustainable Growth
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BRUSSELS, 20 June 2022
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ESG Ratings are meant to offer a snapshot evaluation of the impact of ESG (environmental, social and governance) factors on a company as well as the company’s impact on the outside world.
As ESG investing is becoming increasingly mainstream, these ratings are being widely used by a variety of stakeholders at a growing rate. In particular, there has been an increasing focus on ESG factors and their relationship with financial performance. In other words, an increasingly common question is whether and to which extent ESG factors impact an entity’s creditworthiness. On top of this, at a time when the financial industry is being called to closely assess the ESG impact of their portfolio, both on a voluntary basis and as a result of mandatory EU legislation, these ESG ratings can potentially serve as a useful tool.
While on the one side ESG ratings could contribute to filling current data gaps in the area of sustainability, the rapid development and increasing reliance on such ratings by market participants has led to the proliferation of agencies offering these products, which investors and other stakeholders rely on. What has, however, been observed is that there are significant divergences between the rankings produced by different agencies. This can be traced back to at least one underlying rationale: different rating providers use different methodological approaches when providing ESG ratings. The approaches vary across providers and different weights are attributed to the single components of the score (i.e., to the ‘E’, ‘S’, or ‘G’), leading to issues of comparability across ratings. It goes without saying that if the same methodological approach is not applied, comparing results can be quite arduous. In the process of making a portfolio selection or investment decision, increasing transparency about the underlying methodologies, data sources, and weightings ESG rating providers are using is therefore crucial.
Another relevant area of concern is ESG ratings providers’ accessibility to this expanding market. At the current state of things, ratings are mainly provided by large market players headquartered outside the EU. The combination of these two elements, raises a few issues. First, it limits access to the market by smaller providers, which face entry barriers linked to high data collection costs and brand recognition of larger providers. The exponential growth in demand for ESG data should be matched by an equal, or at least similar, expansion of the relevant market. The EU ESG regulatory landscape is growing rapidly and facilitating access to the market also to smaller ESG rating providers may be particularly beneficial to cater to regional specificities. Moreover, few providers cannot cover the totality of demand for ESG ratings, especially in Europe, where the need for readily available ESG data reflects the rapid progress of sustainability-related disclosure requirements. Not matching the growing demand with a larger market will ultimately be detrimental in terms of the quality of the ratings provided. Second, over-reliance on few non-European providers and the resulting lack of competition may lead to higher costs for European companies. It is also important to ensure that ESG ratings are reflective of the fast-changing EU ESG legislative landscape.
So, how can we ensure the most is made of this essential tool? The EU certainly needs a coordinated approach, and this could be achieved through a common methodological framework bringing transparency and greater harmonization amongst ESG ratings against a current reality of unregulated data providers operating in the EU market.
With the EU standing as a frontrunner in the field of sustainability, it is crucial that we ensure a well-functioning, reliable, and transparent system for ESG ratings, which should provide meaningful and high-quality assessments of the ESG performance of companies.
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For more information:
Marta Morellato, Financing Sustainable Growth, m.morellato@ebf.eu
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Gianluca Manca, Head of Sustainability at Eurizon Capital, on Corporate sustainability reporting, SMEs and the future of sustainability
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BRUSSELS, 17 March 2022 – On April 21st, 2021, the European Commission adopted an ambitious and comprehensive package of measures to channel funding towards sustainable activities. This package includes the proposal for a Corporate Sustainability Reporting Directive (CSRD) aiming – over time – to bring sustainability reporting on a par with financial reporting. We sat down with Gianluca Manca, Head of Sustainability at Eurizon Capital, EFRAG Project Task Force member, and Chair of the EBF’s ESG Reporting Task Force to discuss the developments concerning sustainability reporting in the context of the ambitious EU sustainability agenda and the current geopolitical tensions.
What is the Commission’s objective with its proposal for a Corporate Sustainability Reporting Directive and what does it have to offer compared to its predecessor, the Non-Financial Reporting Directive (NFRD)?
The EU wants to politically involve the corporate world to foster transparency and ignite virtuous behaviour. In order to do so, the EU has targeted the financial world to be the stimulus and compass of the transition towards a cleaner and better functioning world.
The NFRD, Taxonomy, Sustainable Finance Disclosure Regulation (SFDR), and the upcoming CSRD (just to name the most widespread) are legislative packages that impact finance heavily in different ways, from Credit Institutions to Asset Managers and Insurers. While the NFRD worked as a tutoring tool for corporations, the upcoming CSRD will change the rules of financing.
The legislative impetus that we are witnessing in Europe is proof of widespread political awareness which translates into norms, regulations, and legislative pieces. In this context, the newly proposed CSRD (as the future successor to the NFRD) has set within its scope 1) large companies and 2) all companies listed in EU regulated markets (excluding micro enterprises) covering up to roughly 49.000 companies (in the NFRD the scope covered 11700 companies). The proposal envisages two standards: one for large companies and one for listed SMEs, specifying that all those not in scope should report voluntarily (based on the standard for listed SMEs). In fact, the proposed text envisions that the Commission shall adopt delegated acts to provide sustainability reporting standards proportionate to the capabilities and characteristics of small and medium-sized undertakings.
What are the main concerns related to the proposal to require mandatory reporting from listed SMEs?
If we weigh and match SMEs capabilities to respond to the directive and the needs of stakeholder’s, including financial institution’s, public authorities and NGOs, we could stumble into a dilemma. On the one hand an excessively simplistic standard might be inadequate to meet the reporting and disclosure requirements of the numerous and diverse stakeholders; on the other hand, an excessively demanding standard might not be feasible, proportionate or cost-effective for SMEs. This starting point has been widely elaborated by committees and parliamentarians whose outcome recently resulted in a compromise text. This text reports numerous amendments that mainly involve the scope of the proposal, also highlighting the need for a list of high-risk small and medium companies.
In such a scenario, even though the majority of European SMEs would not be subject to any obligatory reporting standards, they would, nonetheless, be impacted as a result of the so called “trickle-down effect”, as large undertakings will have to report on their entire value chain. This effect, therefore, implies that large companies, which are in scope, will require full disclosure from their suppliers to comply with their reporting duties. Hence, the SMEs realm might therefore be split into those who are reporting in compliance with the directive (listed SMEs), those reporting in response to the request of larger clients or financial institutions, those not reporting at all (mainly business-to-consumer enterprises), and those that wish to report voluntarily to explain their sustainability journey and/or approach in light of the commercial or competitive advantage which could result from their positive performance. With these premises the European Financial Reporting Advisory Group (EFRAG), mandated by the European Commission to develop the reporting standards, is working hard to define reporting standards that are adequate and proportionate to allow the sustainability reporting for the widest possible number of SMEs, and not only listed SMEs.
How can a simplified and voluntary reporting standard benefit smaller companies?
One of the concepts EFRAG has recently highlighted is that the reporting tool should be envisaged and serve as a facilitator for smaller companies to address their story and their role in the sustainability revolution. Accurate and effective transparency will certainly lead to better market positioning, attractivity at direct client’s level and additional risk control. Companies reporting voluntarily will also be better positioned – satisfying the requests of financial institutions and more likely being subject to quicker assessments and successful financing.
The invasion of Ukraine has brought our attention to Russia’s role as one of the top global suppliers of fossil fuels. Do you think this will consequently impact the ambitious European sustainability agenda?
The events which are unfolding have certainly impacted the perception of the European sustainability journey. The dramatic Russian invasion of Ukraine is forcing all players to re-evaluate well-established beliefs that were by now embedded in the overall EU strategy, forcing all stakeholders to consider alternative solutions to meet defence and energy needs. In particular, we have come to the realisation that we can no longer rely on instable international relationships for our energy supply and as a consequence this will inevitably influence the approach to investments related to the energy transition as well as the sustainability agenda as a whole.
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For more information:
Alexia Femia, Policy Adviser, Sustainable Finance a.femia@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere
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]]>EBF SUSTAINABLE FINANCE ROUNDUP ARTICLE
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‘Getting to grips with managing climate risk’, Lukas Bornemann, EBF Prudential Policy & Supervision Policy Adviser
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BRUSSELS, 17 March 2022 – In November 2021, the Basel Committee on Banking Supervision (BCBS) issued a consultation on the “Principles for the effective management and supervision of climate-related financial risks”. This is a significant enhancement in the scope of the BCBS global standards, only comparable to the addition of market risk in the 90’s, operational risk in the 2000’s or liquidity risk in the 2010’s. The Basel Committee will define, in a high-level and principle-based manner, what banks and supervisors should look out for when discussing the topic of climate risk. In its consultative document, the BCBS has laid out principles that apply both to banks and supervisors in a qualitative manner. The principles range from corporate governance aspects, such as implementing processes that allow banks to properly understand and assess their climate risk, guidance on the integration of climate risk in their capital and liquidity adequacy frameworks, to scenario analysis that would be used to assess banks’ resilience to climate risk. Furthermore, the BCBS has taken the opportunity to also address supervisors who will need to ensure that the BCBS principles are respected by their supervisees.
Considering the global nature of the climate risk challenge, the BCBS is the right institution to adopt a supranational approach for the banking sector, thus pursuing a coordinated approach for example concerning the reporting and disclosure of information. With a broader view on harmonization, it is important that supervisors have the necessary flexibility to reconcile the BCBS principles with their own expectations. Many supervisors have already progressed on this and developed their own expectations and communicated them to the banking sector. Therefore, the mentioning of proportionality in the consultative document is quite relevant. At the same time, it would be preferable that the discussions within national jurisdictions feed back into the discussions at the BCBS and inform the future regulatory output of the BCBS.
The main challenge for regulators and supervisors in the next years will be finding the appropriate treatment of climate risks in banks’ capital and liquidity frameworks. It looks like policy makers will be faced with a conundrum that is not easy to resolve. On the one hand, everyone agrees that climate risks will appear in the future and that they will have an impact on banks’ clients. On the other hand, the transition towards a more sustainable economy is already underway. However, what is not clear is how exactly the risks will be materializing.
The key persisting issue is the lack of data as to how this will play out. First, there is uncertainty around the physical aspect of the climate change challenge. While it is certain that it will happen, two questions remain, which are “How?” and “When?”, referring to the speed and magnitude, and the non-linearity of the impact. Second, there is the regulatory uncertainty that banks are faced with, and which leaves questions about key aspects of the overall issue, most importantly about the policies governments will choose to fight climate change. Third, there is a complex sum of interplaying factors that need to be understood, such as the transformation capacities of the industry, public and industrial policies supporting transition, general economic, social and political developments such as inflation, or the availability of certain raw materials or technological developments. However, more information on this would be needed to define general quantitative rules and expectations for capital charges, which tend to be the outcomes of careful calibrations. In this respect, a more appropriate solution will be to maintain the dialogue between supervisors and banks and use available tools, like the ECB climate risk stress test or the thematic review, to develop a deep understanding of the impact of climate risk on banks and take the necessary measures if climate risk is not accounted for appropriately.
What is also clear is that banks alone will not be able to bring about the so-called “greening” of the economy on their own. Banks are an important piece in the overall puzzle, but it should not be forgotten that in the case of the EU, the member states will need to integrate their fight against climate change into their overall policy objectives. Such clarity from the public sector will be essential for banks to be able to take up their commitments within the confines of the societal compromise that is reflected in EU member states’ climate objectives.
You can read the EBF’s official response to the BCBS Consultation ‘Principles for the effective management and supervision of climate-related financial risks’ here.
For more information:
Lukas Bornemann, EBF Prudential Policy & Supervision Policy Adviser, l.Bornemann@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Subscribe to the EBF Weekly + FinReg Agenda
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Stefano Spinaci, Policy Analyst at EPRS, on the European Green Bond Standard
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BRUSSELS, 17 March 2022 – On July 6th, 2021, the European Commission proposed a Regulation on a voluntary European Green Bond Standard (EU GBS) with the intention of setting a ‘gold standard’ for how companies and public authorities can use green bonds to raise funds on capital markets to finance ambitious investments, while meeting tough sustainability requirements and protecting investors from greenwashing. We sat down with Stefano Spinaci, Policy Analyst at the European Parliamentary Research Service (EPRS), to discuss the Commission’s proposal, the elements that distinguish the European Green Bond Standard, and where we are currently in the legislative process.
What are the defining elements of the European Green Bond Standard? How does it set itself apart from other existing standards for green bonds?
The main distinctive element of the proposed European Green Bond Standard is full alignment with the EU taxonomy, as issuers would have to allocate 100 % of the proceeds of the bond to finance taxonomy-aligned economic activities, before maturity of the bond. The new standard would, in addition, allow the funding of long-term projects (up to 10 years) for those economic activities that are not yet aligned with the EU taxonomy, helping issuers finance their green transition. In terms of transparency, the issuers would report firstly on their commitment to align with the standard – to be done annually on the allocation of proceeds – and finally on the aggregate environmental impact. These disclosures would undergo thorough pre-issuance and post-issuance reviews by external reviewers.
The proposal would also establish a registration system and supervisory framework for external reviewers, managed by ESMA. The registered external reviewers would ensure compliance with the EU GBS Regulation, and particularly the alignment of the funded projects with the EU taxonomy. ESMA’s supervisory role would allow it to investigate complaints, impose fines and, if necessary, withdraw registration.
Currently, there are two existing market standards: the Green Bond Principles (GBP) of the International Capital Market Association (ICMA), and the Climate Bond Standard of the Climate Bonds Initiative (CBI).
The ICMA GBP is the dominant market standard, and it is considered the de facto global standard. While the standard defines a clear process for project selection and allocation of funds, it lacks a clear definition of green economic activities. It provides a list of eligible green projects categories, while allowing issuers to look to international/regional and national taxonomies for project eligibility guidance. In terms of external verification, the ICMA GPB simply recommends a third-party external review, while the EU GBS would establish a supervisory framework for external reviewers. Other mandatory requirements in the EU GBS are expressed as recommendations in the ICMA GBP, for example the publication of a framework document (“factsheet” for the EU GBS) before the issuance, the pre-issuance external review on the framework document, and the post-issuance external review of the final allocation report.
Currently, about a quarter of green bonds worldwide are issued under the Climate Bond Standard developed by the CBI. This standard focuses on low-carbon and climate resilience objectives. Its own Climate Bonds Taxonomy covers eight sectors and provides related screening criteria. In comparison, the EU Taxonomy, and therefore the EU GBS, covers a broader range of objectives (eg. biodiversity, circular economy, water use and protection), further than the climate ones. The external review requirements are quite similar to the EU GBS, and external reviewers must be pre-approved by CBI, while impact reporting is only recommended.
What will ensure that the EU GBS will become a ‘gold standard’?
The EU is already a global leader in green bonds. Data on 2021 are not yet fully available yet, but if we look at 2020 data, 48 % of global issuances of green bonds was denominated in euros, and 51 % of the global volume of green bonds was issued in the EU. This is also thanks to the European banking sector, which is excelling in the global market. In addition to this, Europe has been a pioneer in the green bond market thanks to the world’s first green bond issued by the EIB in 2007. The GBS is of course tightly linked to the other elements of the EU’s green finance agenda, and especially the EU Taxonomy, which will provide certainty thanks to its scientific basis. In order to facilitate the uptake of the EU GBS, the European Parliament deemed that a significant share of the EU bonds should be issued in the context of the Recovery plan for Europe and on the basis of the EU GBS. The final aim is to incentivize investments and further issuance of EU GBs. The European Central Bank has suggested that, over time, it will be essential to assess and monitor the attractiveness of the EU GBS compared to market standards and/or other jurisdictions’ statutory green bond labels.
How has the European Commission’s proposal for the EU GBS Regulation been received by stakeholders?
It is clear that green bonds are subject of great interest in the market. Although it lies in the hands of the various stakeholders to outline their views, some of the most debated provisions are the nature of the standard (voluntary vs. mandatory), 100 % taxonomy alignment (or allowing some flexibility), partial grandfathering (vs full or no grandfathering) in the case of evolving technical screening criteria under the EU Taxonomy. Various comments concern the necessity to include activities and sectors currently not covered by the EU taxonomy, and to facilitate access to the instrument for transitional activities and for SMEs. Some suggest a sustainability standard including social and governance factors. On request by the European Parliament, the European Central Bank has also provided an opinion on the proposal. The ECB expresses its favor for full grandfathering because it would help maintain financial stability and certainty for bond issuers and investors, and consequently facilitate the functioning and growth of the European Green Bonds market. To know more about stakeholders’ views, and generally about the EU GBS, I invite you to read our EPRS briefing “European green bonds. A standard for Europe, open to the world”.
Where are we currently in the legislative process?
Following the publication of the Commission’s proposal in July 2021, it is being examined by the co-legislators. In the European Parliament, the Committee on Economic and Monetary Affairs (ECON) is responsible for this file, and has appointed Paul Tang (S&D, The Netherlands) as rapporteur. The Committee on Budgets (BUDG) and the Committee on the Environment, Public Health and Food Safety (ENVI) have been asked to give an opinion on the legislative proposal. At the end of November, the rapporteur published his draft report and proposals for amendments have been introduced in the course of the following months by the shadow rapporteurs and other ECON members. ECON is supposed to adopt its report at the end of March (the indicative date is 31 March), in order to get a mandate to negotiate during the April plenary session (4-7 April) or at the latest during the next plenary session (2-5 May). In the Council, the working party on financial services held various meetings to discuss the dossier under the Slovenian Presidency (second half of 2021) and is continuing its work under the current French Presidency, in order to reach agreement amongst Member States on a negotiating mandate.
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For more information:
Alexia Femia, Policy Adviser, Sustainable Finance a.femia@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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EBF SUSTAINABLE FINANCE ROUNDUP ARTICLE
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‘Practical approaches to applying the EU Taxonomy to bank lending’, EBF-UNEP FI joint report
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BRUSSELS, 17 March 2022 – At a time when regulation is being rolled out at overwhelming speed with the aim of incorporating sustainability in all areas of business, leading European banks came together as part of the second phase of the joint EBF-UNEP FI project to discuss the application of the EU Taxonomy, but also to explore its potential to facilitate engagement with customers in the evolving business and regulatory environment.
The year-long discussion and exchange of views and practices itself benefited and moved the banking industry forward as a whole. The value of the resulting report, “Practical approaches to applying the EU Taxonomy to bank lending”, is undisputable for banks that will need to implement the Taxonomy regulation and the related disclosure requirements. In addition, the insight provided will help companies understand the possible impact on their business, the direction of travel and how engagement between banks and companies may evolve. The report will also help stakeholders understand and demystify the Green Asset Ratio and hopefully provide helpful insights and inputs to regulators and legislators as they further develop the sustainable finance framework.
First and foremost, the report covers the regulatory application of the EU Taxonomy (Section A). It focuses on disclosure requirements under the EU Taxonomy Disclosure Delegated Act looking at the practical aspects of reporting for banks, such as the use of NACE codes, reporting on general- purpose lending, and possible processes for the implementation of the regulation. It also aims to facilitate the understanding of the Green Asset Ratio for external stakeholders.
The report then investigates the possible non-regulatory applications of the EU Taxonomy.
Within Section B, the report explores how the EU Taxonomy could be further used to gather EU Taxonomy compatible information for banks’ clients who do not yet have an obligation to disclose under the Article 8 Delegated Act of the EU Taxonomy Regulation, or in other words SMEs and non-EU companies, often referred to as non-NFRD companies. At the time of finalization of this report, there was no mandatory obligation for banks to report the Taxonomy alignment of their exposures to non-NFRD companies, although the EBA is proposing mandatory KPIs on such exposures in their final draft of binding standards on Pillar 3 disclosures on ESG risks, which is still subject of adoption process of the European Commission. This chapter also addresses compliance with minimum safeguards of the EU Taxonomy regulation and simple tools such as a questionnaire that could be used to gather EU Taxonomy-aligned data as a starting point.
It is important that banks finance all activities capable of accelerating companies’ transition. Financial solutions based on companies’ transition plans could, in the future gain importance and, in a complementary manner to the financing of the EU Taxonomy aligned activities, substantially contribute to achieving the global objectives of net zero.
Finally, Section C discusses in an exploratory way, how the EU Taxonomy could be used by banks that wish to engage with clients whose economic activities are eligible for analysis under the EU Taxonomy but are not yet aligned with the listed Technical Screening Criteria. Such an application of the EU Taxonomy for client engagement (e.g., using the Technical Screen Criteria to set targets) is still at an early stage.
This section provides the participating banks’ initial thoughts on the matter and outlines a simple transition engagement tool—a step-by-step approach for banks that wish to evaluate the degree of misalignment of their clients ‘activities with the EU Taxonomy, to choose the appropriate engagement strategy. It further explores other possible financing solutions based on the transition plans of companies. Finally, this section looks at possibilities of mapping exposures to the EU Taxonomy based on NACE-sub activities and products codes of companies to actively steer the financing of sustainable activities.
As invaluable as the report is, it does not have all the answers. There is lot of work still to be done. Many more discussions on the practical application of the taxonomy can be expected both in the corporate sector and banks. The engagement with SMEs will be even more challenging. Should the Commission approve the mandatory taxonomy disclosure of banks on their SME portfolio as proposed by the EBA, we will need further discussions not only on how to find a right balance between direct engagement and use of practical solutions but also discussions on how to bring the EU Taxonomy closer to SMEs.
It is not about the willingness of the SMEs to report taxonomy alignment, it is about their capacities to do so as information will be needed to assess all exposures, not only the “green financial products”. No one has a silver bullet or definitive solutions to put on the table. We need to work together, in a structured dialogue between authorities, the business sector and banks with the objective to step up clear communication and educational efforts and to find common practical solutions at sectoral level including defining clear sectoral transition plans.
Only through understanding of each other’s objectives, challenges and needs, will we be able to achieve our common goals. This report is a first step to such a dialogue as it will help better understand the current thinking within the banking industry.
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For more information:
Denisa Avermaete, Senior Policy Adviser, Susatinable Finance d.avermaete@ebf.eu
Alexia Femia, Policy Adviser, Sustainable Finance a.femia@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post ‘Practical approaches to applying the EU Taxonomy to bank lending’, EBF-UNEP FI joint report appeared first on EBF.
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