At the beginning of August 2021, the United Nations Intergovernmental Panel on Climate Change released a milestone assessment that drew an “unequivocal” link between human activity and global warming. The Secretary-General of the UN made it clear that the conclusions of the report mean one thing…“code red for humanity.”

Meanwhile, money managers are “flooded with cash” chasing ethical causes. According to Bloomberg Intelligence, in just four years the global market for ESG investing is set to exceed $50 trillion – more than 1/3 of global AUM.

As of 2021, what percentage of European exchange-traded products are ESG Funds

The question is how much of this is simply “greenwashing”?

In spite of being ahead of the curve when implementing regulations to prevent greenwashing, Europe, and European Asset Managers, admitted roughly $2 trillion, originally classified as climate and social investing, didn’t live up to the label. This figure is just for the couple of years preceding the new ESG regulations.  

The first phase of the Sustainable Finance Disclosure Regulation (SFDR) came into effect in March this year. All European Asset Managers now need to adapt and embrace a uniform set of reporting standards, designed to fight investment “greenwashing”. They are supposed to categorise investment products as light green (Article 8) and dark green (Article 9).

“What defines an Article 8, and even Article 9 product, is still very much in the eye of the beholder. And we’ve seen quite a few diverging assessments of otherwise similar products and strategies.

~Baard Bringedal, Chief Investment Officer at Storebrand Asset Management


A recent survey by Bloomberg of 20 major European banks and Asset Managers, confirms Bringedal’s words and strongly suggests that the newly imposed regulations leave too much room for guess work and interpretation. 

One of the latest issues is the discovery that around 80% of the funds labeled as sustainable or “light green”, are also invested in fossil fuel companies. Furthermore, in a few cases, fossil fuel investments account for as much as 50% of the “sustainable” fund’s portfolio. 

“It appears that with the implementation of the SFDR, the whole world has changed. But in reality it’s recolouring old businesses with new names.”

~ the head of a Europe-based emerging markets-focused infrastructure Asset Manager

One possible reason for this is the lack of a clear and mutually accepted definition of sustainability. Put simply, sustainability means different things to different people. This leaves too much room for individual interpretation of the term and thus a lack of cohesion when addressing how ‘sustainable’ an investment may be. For example, a fossil fuel company may be rated as light green and sustainable not because of any kind of positive ecological and environmental impact, but because it is deemed to have a positive social impact. 

Another “blind spot” is the absence of numerical thresholds or targets for classifying light or dark green funds; just a change in wording. An Article 8 fund must “promote” environmental or social objectives, while an Article 9 funds “contribute” to environmental or social objectives.

“The articles are so wide in their definitions that managers can take any social or environmental characteristics, no matter how minimal, and market their fund as sustainable,”

~ Kristian Håkansson, Head of Product and Marketing at Swedish fund house SPP

So who are these labels really for?

“I don’t think the average retail client investing in a ‘sustainable’ fund, according to an EU regulation, would expect to be getting up to 50% exposure to fossil fuels. But it is perfectly allowed within the regulation,”

~  SPP’s Håkansson – the firm, part of Norwegian Asset Manager Storebrand, has categorised all of its Funds as Article 8 or 9.

Though the latest UN report makes clear the dangers of climate change, money managers are still seeking loopholes, relying on rising confusion and unclear regulatory framework. In response, the European authorities have proposed additional so-called ‘technical standards’ to be adopted later this year, after financial market participants were asked for their input. Climate change is already costing lives; one has to look no further than the recent floods in Western Germany and Belgium. Regulations must align with and reflect the severity of this threat.

Is your firm ready to face the challenges of SFDR new reporting standards? 

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