This document presents the ABBL’s response to the European Commission’s “Have Your Say” consultation on the proposed amendments to the Sustainable Finance Disclosure Regulation (SFDR). Based on feedback from its members, the Luxembourg Bankers’ Association outlines key recommendations to improve the clarity, efficiency and operational feasibility of the sustainable finance regulatory framework. The paper highlights five priority areas, including the introduction of clearer product classifications, the reduction of administrative burdens through the removal of certain entity-level disclosure obligations, improved communication of sustainability information for retail clients, enhanced interoperability between ESG-related regulations, and clarification of the concept of sustainable investment in relation to the MiFID framework.
