Position Paper on Voluntary Sustainability Labels as Part of the SFDR 2.0

As part of the revision of SFDR 2.0, a consultation response was submitted to the European Commission addressing the role of voluntary sustainability labels within the European regulatory framework.

The starting point is the observation that the proposed regulatory product categories provide an important foundation for improving transparency and comparability, but in practice cannot fully capture all differences in sustainable investment strategies.

The response therefore advocates for the continued explicit recognition of voluntary sustainability labels within the SFDR framework. Such labels can serve as a complementary instrument to highlight sustainability performance beyond regulatory minimum requirements, strengthen the credibility of sustainability claims, and provide additional guidance for investors.

A combination of a regulatory baseline and voluntary quality differentiation can help to showcase best practices in the market, create incentives for innovation, and enhance the overall credibility of sustainable financial products.

Consultation submission:
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14666-Revision-of-EU-rules-on-sustainable-finance-disclosure/F33387837_en

Participating organisations:
F.I.R.S.T. e.V. · Advanced Impact Research GmbH (AIR) · Forum Nachhaltige Geldanlage e.V. (FNG) · University of Hamburg (UHH)

AIR would like to thank all participating partners and experts for the constructive collaboration and valuable contributions.