2020年更新的可持續金融戰略 - 歐洲銀行聯合會（英文版）（16頁）.pdf

1、 1 Renewed Sustainable Finance Strategy Important considerations from the banking sector Focus on usability and enforceability of the currently developed tools and requirements Ensure clarity and stability of political and regulatory environment Reduce complexity and ensure consistency across EU leg

2、islation, regulation, and standards Enhance availability, reliability, and comparability of material ESG data by means of European reporting standard and central ESG Data Register Develop a uniform definition of ESG risk and criteria for understanding the impact of ESG risks on corporations Provide

3、corporates and financial institutions with analysis methods and tools which can help to assess the impact of ESG risks on lending Favor innovation in sustainable finance to identify new instrument which can better support the transition toward sustainable business models (es. ESG-Linked Loans; SDG K

4、PI-linked bonds; Impact Loan; Blended Finance products; Green Project Finance etc.) Address Transition Finance, to allow all companies committed to transition to access sustainable finance Develop minimum social criteria and ensure just transition Introduce incentives and enhance financial viability

5、 of sustainable activities (e.g. risk sharing mechanism) Promote global approach and level playing field 22 July RENEWED EU SUSTAINABLE FINANCE STRATEGY Important considerations from the banking sector 2 Sustainability as an opportunity The banking sector sees the EU sustainability agenda as an oppo

6、rtunity to further promote the role of the sector within the society and align its interest and strategies with clients, investors, employees, and society in general. The fast-growing sustainability markets provide a positive competition edge for market leaders. To mainstream sustainability in the f

7、inancial sector, it must become highly relevant to the business sector, including SMEs. An opportunity comes from placing more focus at a national and local community level as banks are an integral part of local communities and can play a key role in driving local initiatives in delivering on the 20

8、30 climate and energy targets. Banks also see opportunities in combining Covid-19 related recovery stimuluses with sustainability objectives and accelerating of social aspects of sustainability. This would include enlarging just transition fund to cover social convergence and increasing the resilien

9、ce of supply chains towards increased self-sufficiency of EU and decreased overreliance on third countries suppliers. To improve environmental conditions, it is necessary to transition from a linear economy model to a circular one. This transition is an even more pressing need for countries with a r

10、elevant manufacturing sector and, at the same time, a scarce availability of raw materials. Global approach While the EU championship in the fight against climate change is to be appreciated, competitive implications for the EU Economy, possible frictions in international capital flows in particular

11、 in the short terms, should EU press its ambitions unilaterally, are to be expected. Climate change is a global challenge, requiring a global response. The current pandemic and economic crisis have reinforced the need for a comprehensive and global approach to cope with the heightened asymmetries, w

12、eaknesses and inequalities of our system that must be properly considered to achieve sustainable, inclusive, and fair development. The globalization requires more international as well as institutional cooperation for the successful and effective transition to sustainability. In fact, even a single

13、jurisdiction arbitrage could severely dent the effort made by other committing countries. RENEWED EU SUSTAINABLE FINANCE STRATEGY Important considerations from the banking sector 3 At international level, the EU trade policy could be a useful tool to promote the fight against climate change, environ

14、mental degradation and human trafficking. The role of climate in trade deals could be strengthened. Also, tax policies such as the carbon tax could be a way to avoid a loss of competitiveness for European firms internalizing the costs associated in particular with climate change. Financial industry

15、is much more internationally interrelated then other kind of industrial value chains. Currently there is no systematic approach to measure and benchmark the progress and performance of sustainable banking at a global level. Given this global interconnectedness, there is a need for wider internationa

16、l standardization to the maximum possible extent for financial sector. Reducing consistency and complexity, improving usability As with any major transformation, there are challenges that will need to be overcome for the EU to meet their sustainability targets as envisaged. The complexity of the sus

17、tainable finance framework with partly overlapping initiatives and requirements is increasing, with a significant obligation placed on the financial services sector. In some instances, a direct regulation of businesses should be considered instead of indirect measures via the financial sector. Incre

18、ased complexity will negatively impact effectivity as well as usability of the tools developed by the EU. Now, reporting/disclosure obligations arise under numerous different pieces of proposed legislation and guidelines, each with slightly different scopes and definitions. Lack of consistency in re

19、porting makes it difficult to assess a banks portfolio. To avoid subjectivity and increase comparability, a simple set of metrics and mandatory disclosures that all industries had to use and report on would help achieve a better outcome in the short term and could be built on over time as understand

20、ing improves. The focus of reporting requirement should be on high informational value and materiality. Only perfect alignment between reporting requirements under the reviewed Non-Financial Reporting Directive (NFRD), the Sustainable Finance Disclosure Regulation, the Capital Requirements Regulatio

21、n Pillar II disclosures and the Taxonomy Regulation, will ensure the usefulness of companies data that banks will have to report. RENEWED EU SUSTAINABLE FINANCE STRATEGY Important considerations from the banking sector 4 The EU Taxonomy is a starting point for the quantification of exposures, the de

22、velopment of financial products and services on a comparable basis and increase of the climate change related financial assets. The success of the EU taxonomy and further developments will depend on its operationality and potential to be used in an automated way. Clear tagging of green activities li

23、nked to the codes already used by banks and a clear link to the national laws is lagging. Shared interests of EU Member States, supervisors, investors, banks, research institutes and companies in sustainability data requires a common language with the possibility to exchange data in automated system

24、s. To classify and report on green expenditure, further changes will be needed in order to align reporting on Environmental Goods and Services Accounts, taxonomy compliant activities and NFRD reporting in a coherent manner. A common language for sustainability needs at least two structural elements:

25、 a sustainability taxonomy and a nomenclature, or classification system. Please see EBF proposal on the usability of the taxonomy on the EBF website : https:/www.ebf.eu/sustainable-finance/usability-of-the-taxonomy-ebf-responds-to- european-commissios-technical-expert-group-consultation/ The EBF is,

26、 together with UNEP FI undertaking a project on the possible use of the EU taxonomy for certain banking products which is expected to further contribute to the debate on the usability of the taxonomy for banks. The project is expected to conclude by the end of 2020. Data challenge: call for a centra

27、l database Environmental and social information may not be available in certain markets and may not be presented for financial market participants in understandable and decision useful ways. If companies are not able to provide the data required by the EU Taxonomy, there is a risk of under- represen

28、tation of the environmentally sustainable sectors and/or the risk of an information gap between larger companies and small and medium- sized enterprises. A unique reference capable of enabling the standardization and collection of relevant ESG information and sources is therefore advisable. RENEWED

29、EU SUSTAINABLE FINANCE STRATEGY Important considerations from the banking sector 5 Effectiveness will increase and costs of implementation will decrease if companies can report only once to a central data register, which financial institutions can access for application to finance decisions. There i

30、s therefore a need for a centralized EU hub (register) where relevant, reliable, comparable, and legitimate ESG data, based on a common reporting standard are available either for free or at affordable cost. The Commission should build or support, based on existing solutions and infrastructures alre

31、ady in place, an EU infrastructure that could collect periodically, with the help of new reading technologies, existing climate change mitigation and adaptation data of companies that published non-financial statements under the NFRD and other available relevant information, ESG metrics and relevant

32、 data points. It should also be possible to upload additional information to the register on a voluntary basis, based on a common standard. The EU should also open its databases that collect environmental reporting data and make those re-usable for finance providers via this central register. Enviro

33、nmental Goods and Services Sectors (EGSS) activities under the UN System for Environmental Economic Accounting should be complementary to the data that companies and financial institutions report. This data is critical for financing, and to track the economic performance of sustainable activities. E

34、SG research and rating Currently the ESG research and rating market is very fragmented and the level of comparability of different methodologies is very low and does not allow for an easy use. The lack of comparability is due to the lack of transparency and uniformity of the rating scales, criteria

35、and objectives as well as lack of standardized disclosures and, for the time being, absence of a common taxonomy. The providers offer different sensitivities to different issues or combining a set of factors that may be wholly or partially unrelated and sometimes offsetting. The resulting ratings is

36、sued by ESG Ratings agencies tend to differ. A company may be considered very high risk, medium risk, or low risk, at the same time, when rated by three different agencies and peers comparison is also difficult. On top, data often seem to lack update promptness, indication of sources and quality ass

37、urance. There is a need for more transparency of the methodologies used by the rating providers. While technical algorithms and proprietary information does not have to be disclosed, it would be useful to understand what material information rating providers are looking at and how this is being used

38、. Agencies need to be accountable for keeping data up to date and applying consistent approaches to assessing similar companies RENEWED EU SUSTAINABLE FINANCE STRATEGY Important considerations from the banking sector 6 Ratings tend to cluster companies into sectors in a heterogeneous manner without

39、providing a granular analysis of the sectors. This high-level sector approach implies that the materiality applied to a sector quite often does not correspond to what is relevant at individual company level. To this end it would be helpful to include a tag whereby the rating would explain whether th

40、e sector aggregation is automatic or has been manually allocated by an analyst. Data providers are still focusing on exclusions and relative ESG performance while there is a need for increased focus and data on positive impact. However, the quality of data reporting by numerous agents has improved i

41、n the last few years and further improvement is expected with the implementation of the EU taxonomy. There are some positive trends thanks to the increased companies disclosure, increased coverage of companies by data providers and more regular update of data. While ratings were traditionally very b

42、ackward- looking and had little predictive value, there is an emerging tendency by data providers to focus on material issues/risks and their likely impact on companies performance. It is further necessary to shift from backward-looking perspective and excessive focus on disclosure ESG compliance (t

43、ick the box) to ESG strategic considerations. With the development of the ESG data range covering different degrees of granularity, the challenge will be to find the right balance between usability and granularity. While the data quality has improved, data providers are still often focusing on large

44、 corporates. The lack of coverage for SMEs is one of the main challenges. Another point of possible concerns are the costs and access to ESG data. We believe that strong support by the EU in this domain is necessary, so that financial intermediaries can access sufficient databases and research at Eu

45、ropean level. The proposed EU centralized data register could substantially improve the data availability and analysis and increase understanding and management of the ESG risks. Transition The current sustainable finance is too much investor driven, while in a bank financed, SME based economy, bank

46、s will play an important role to accompany the companies in transition. Sustainable Finance is also too focused on green financial investments and products. There should be more focus and discussion on transition finance and role of banks going forward, including appropriateness, usefulness and oper

47、ationality of currently developed, investor centric EU tools in banks. Countries characterized by a higher concentration of SMEs face particularly difficult challenges in pursuing sustainable investments. While start-ups and SMEs have the potential to be a major driver of innovation for sustainable

48、development, more attention should be paid to their financial needs. RENEWED EU SUSTAINABLE FINANCE STRATEGY Important considerations from the banking sector 7 The Public Authorities and financial institutions should cooperate to identify mechanisms for complementing traditional sources of credit fo

49、r companies including SMEs operating in the green economy with more sophisticated financial instruments that allow a longer-term view. Emerging solutions could include fintech, crowdfunding for sustainable projects and impact finance. Banks will also play a key role in supporting companies of all sizes that do not operate in the green sectors in their transition to more sustainable business models. The clarity and stabil