Sustainability Committee

DUFAS responds to financial sector climate action consultation

Views & publications Consultation response

Late last year, the Ministry of Finance published its long-awaited consultation for the "Financial Sector Climate Measures. We underline the role of the financial sector in the climate and energy transition. This is demonstrated, for example, by entering into the 2019 National Financial Sector Climate Commitment, in which a large number of asset managers have declared their commitment to participate in financing the energy transition and contributing to the goals of the Paris Climate Agreement.

We therefore fully understand the Ministry of Finance's exploration and desire to examine whether the climate and energy transition can be accelerated. That is why DUFAS, together with its members, responded to this consultation on February 15.

European legislation and level playing field

The implementation of the comprehensive European legislative package on sustainable finance is still in progress. The full impact in the real economy and on sustainability transitions is not immediately visible. We therefore advocate allowing the European legislation to crystallize first, before taking any new measures, also with a view to a European level playing field. Asset managers are happy to contribute to the proper implementation of European legislation, which is where we believe the most profit can be made.

Asset managers, as investment managers, have a duty of care

In addition, we stress that it is crucial to keep the role of asset managers well in mind when developing possible guidelines, legislation and effort obligations. Asset managers have a special position compared to other financial institutions, where they have a duty of care. We therefore call on the Ministry to take this into account in any introduction of effort obligations to bring financing and investments in line with the goals of the Paris Climate Agreement.

Strengthening shareholder rights and government as facilitator

The climate transition can be further stimulated in various ways. These include strengthening shareholder rights through the CSRD or SRD, so that asset managers have more opportunities to give substance to their engagement policies with respect to companies' sustainability strategy. There is also an important role for the government to act as a facilitator in encouraging transition and transition financing. Examples include facilitating sufficient supply to invest green and wider opportunities for public-private investments that can make a positive contribution to the climate transition.