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.
AIR has submitted a position paper on impact investing as part of the SFDR 2.0 public consultation process. The aim of this joint initiative is to further strengthen the role of impact investing within the EU’s sustainable finance framework.
The paper identifies four key areas for the further development of the regulation: a clear and interoperable definition of “impact”, the recognition of established market standards, the integration of robust and relevant impact KPIs, and a more precise and comprehensive understanding of investor contribution. The proposed adjustments are intended to enhance transparency, comparability, and credibility in the market, while improving practical applicability for financial market participants.
In doing so, the position paper contributes to the development of a consistent and impact-oriented regulatory framework and supports the scaling of impact investing as a tool for achieving measurable social and environmental outcomes.
Consultation submission:
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14666-Revision-of-EU-rules-on-sustainable-finance-disclosure/F33388821_en
Supporting organisations:
DekaBank · Bundesinitiative Impact Investing · Intalcon · Invest in Visions · Tareno AG · Luxcara · Soehnholz ESG GmbH · Roland Kölsch · Steyler Ethik Bank · Forum Nachhaltige Geldanlagen e.V. · ESG Portfolio Management · NEXT Generation Invest · Pax-Bank für Kirche und Caritas eG · GLS Investment Management GmbH · evolutiq Impact Advisory GmbH
AIR would like to thank all participating organisations as well as the experts for their valuable support and contributions.
AIR supported Hamburger Sparkasse (Haspa) in developing an innovative methodology for its first Social Bond Allocation and Impact Report.
The approach follows the recommendations of the International Capital Market Association (ICMA) for portfolio-level Social Bond reporting. It links the use of proceeds to the potential social impact of the financed activities, with a clear regional focus on Hamburg. For this, it is built on an Input–Output–Outcome–Impact logic with sector-specific indicators pragmatically tailored to the available data and using suitable proxies derived from reliable public sources. This enables impact reporting that is transparent, meaningful, and methodologically robust. The report was independently reviewed by ISS ESG, which assessed it as “best market practice.”
The project not only established a methodological foundation for Haspa’s ongoing Social Bond reporting but also generated valuable insights for advancing practical impact reporting more broadly. It demonstrates how credible and decision-relevant impact-reporting approaches can be developed under the data constraints that typically characterise portfolio-level impact reporting in practice. AIR pursues this approach for Social Bonds and other impact-oriented financial products and continues to develop it further together with interested financial institutions.
Further links
The Sustainable Finance Observatory and Advanced Impact Research GmbH invite applications under the tender procedure for the “design and development of an AI-based assessment software platform to streamline and standardize the evaluation of impact potential for financial products”.
This tender is part of the EU-funded project “Impact investments: a proposal for (re)orientation”, cofinanced by the Directorate-General for Employment, Social Affairs and Inclusion of the European Commission.
Deadline for applications: 8th of February 2026, 23h59 (CET).
Applications must be submitted by email only to contact@sf-observatory.org with SFO/2025/OP/01/SF3.0 as the subject line.
The tender documents (invitation to the tender, instructions and proposal form) are published in English. They are available at this link.
🎓 Webinar: Impact Investing in SFDR 2.0
In November 2025, the European Commission proposed a comprehensive reform of the Sustainable Finance Disclosure Regulation (SFDR). The aim is to prevent greenwashing and strengthen transparency and coherence in the sustainable finance market – for the first time with an explicit consideration of impact.
🗓 10 February 2026
⏰ 10:00–11:00 CET
📍 Online
🔗 Access link: https://teams.microsoft.com/dl/launcher/launcher.html?url=%2F_%23%2Fl%2Fmeetup-join%2F19%3Ameeting_ZGJkNjRjMjQtNTI4OS00NWM3LWJkYjItNTljYWE1NzQ3YTE3%40thread.v2%2F0-%3Fcontext%3D%257b%2522Tid%2522%253a%25229ad0b371-61ac-4b97-a203-72c5cbe8dca7%2522%252c%2522Oid%2522%253a%2522d5467c35-9138-4039-80e4-190e170d02a5%2522%257d%26anon%3Dtrue&type=meetup-join&deeplinkId=6355d119-56f9-4b5f-850a-8a6886663405&directDl=true&msLaunch=true&enableMobilePage=true&suppressPrompt=true
📋 Agenda
1️⃣ Overview of SFDR 2.0 with a focus on impact investing
• Prof. Dr. Timo Busch (University of Hamburg)
• Eric Prüßner (Advanced Impact Research)
2️⃣ Discussion & exchange
🤝 With representatives from the financial sector, politics, academia and civil society
❓ Key questions of the webinar:
• What role will impact investments play in the new SFDR?
• Which aspects are decisive for the Level 2 requirements to ensure that impact becomes an effective part of SFDR?
• What do the new product categories (Transition, ESG Basics, Sustainable) mean for practice?
📚 Background
The webinar is part of a research project funded by the German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety, conducted by the University of Hamburg and Advanced Impact Research (AIR), focusing on the development of a methodology for impact measurement of financial products.
More details are available in our proposal paper.
💬 A great opportunity for professional exchange – especially for stakeholders from the financial sector, politics, academia and civil society.
Here you can find the invitation as a PDF (in German only).
#ImpactInvesting #SFDR #SFDR2 #Webinar
The paper “Categories of Sustainability-related Financial Products – A Proposal in the Context of the SFDR-Review” was developed in collaboration between the Sustainable Finance Research Group at the University of Hamburg represented by Prof. Timo Busch, Advanced Impact Research (AIR) and F.I.R.S.T e.V..
The paper “Categories of Sustainability-related Financial Products – A Proposal in the Context of the SFDR-Review” contributes to the ongoing SFDR review by proposing a revised product classification system for sustainability-related financial products. It suggests three main categories – ESG products, transition products, and sustainable products – and integrates impact-aligned and impact-generating dimensions for sustainable and transition products.
Read the full paper here.
The paper “Impact Investing – A Literature Review on the Effectiveness of Investor Impact Mechanisms” was developed in collaboration between the Sustainable Finance Research Group at the University of Hamburg represented by Prof. Timo Busch, Advanced Impact Research (AIR) and F.I.R.S.T e.V.
It explores the potential of different investor mechanisms to generate company-level impact and provides a systematic basis for evaluating their effectiveness. Drawing on existing literature and applying the concept of investor impact potential as an analytical tool, the paper assesses stewardship, capital allocation, and field building for their effectiveness, outlining the potential for each mechanism depending on whether their deployment is direct or indirect. It contributes to existing research by collecting, integrating, and evaluating investor mechanisms based on their investor impact potential.
Read the full paper here.
Advanced Impact Research (AIR) contributed to the position paper “Impact Investing in Infrastructure – Turning Potential into Practice: What does it take to implement Impact Investing in Infrastructure?”, developed by representatives of the Bundesverband Alternative Investments e.V. (BAI) and the Bundesverband Impact Investing e.V. (BVII).
The position paper demonstrates how impact investing can be operationalised within infrastructure and aims to provide a foundation for reflecting on opportunities and challenges in implementing impact investing in this asset class. Serving as a practical resource for investors and decision-makers, the paper encourages the integration of impact-oriented strategies into infrastructure projects, providing concrete case studies for renewable energy, battery storage, energy efficiency, social infrastructure and more.
Read the full paper here.
Over the past few months, Advanced Impact Research (AIR) and numerous representatives of the Bundesverband Alternative Investments e.V. (BAI) and the Bundesinitiative Impact Investing e.V. (BIII) have developed the position paper “Impact Investing in Alternative Investments – why private market investments are particularly suited for impact-generating investments”.
The position paper begins by taking stock of key market concepts and terminology and outlines the main characteristics of impact investments. It also discusses the types of impact products and, in a main section, the relationship between impact investments and regulation and sustainable investments in accordance with Art. 2 (17) SFDR. We hope that this position paper will provide a basis and a starting point for discussion with investors and internal departments.
The whitepaper “Transition Products: Conceptual Clarity & Implementation Guidance” was produced in collaboration between Climate & Company and Advanced Impact Research GmbH (AIR). It provides comprehensive insights into the key design features and suggestions for minimum criteria for transition finance products. At a time when climate change is one of the most pressing global challenges, the financial sector has a crucial role to play in promoting sustainable practices. The paper provides valuable insights and guidance on how to implement financial products that support a transition to a greener economy.
Particular attention is paid to the definition of clear terminologies and consistency with existing sustainability regulations. The aim is to provide investors with clear guidance. The whitepaper aims to contribute to the current discussions on the categorization of financial products with sustainability features in the EU, the UK and beyond.
You can find the complete whitepaper here.
