Response to the consultation on carbon benchmarks

22 August 2018

Consultation response

Brussels, 22 August 2018 – Finance Watch is glad to provide the following contribution to the public consultation on the EC proposal for a regulation amending Regulation (EU) 2016/1011 aimed at defining low carbon benchmarks and positive carbon impact benchmarks.

On related topics, Finance Watch has contributed to the EU public consultations on:

  1. Non-financial corporate reporting in the context of fitness check on the EU framework for public reporting by companies;
  2. EC proposal for a Regulation on disclosure relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341;
  3. EC proposal for a Regulation on the establishment of a framework to facilitate sustainable investment;
  4. [current page] EC proposal for a regulation amending Regulation (EU) 2016/1011 aimed at defining low carbon benchmarks and positive carbon impact benchmarks.

In its responses, Finance Watch has highlighted that:

  1. When revising the guidance on non-financial disclosure, the Commission should not only assess how to integrate Task Force on Climate-related Financial Disclosures (TCFD) recommendations but should require companies to describe both short and long-term plans to reduce CO2 emissions – scope 1, 2 and 3 – and so how they align their business with the Paris Agreement goals.
  2. The definition of sustainability risk shall not be limited to the financial impacts. This would exclude any external costs and so be in contradiction to the aims of sustainable finance agenda.
  3. The sustainable finance platform shall include representatives from civil society and the Commission shall conduct an ex-post assessment of the of the effectiveness of the taxonomy.
  4. The proposal on benchmarks needs major revision, given that the proposed text’s contribution to any of the objectives of the sustainable finance agenda is highly questionable.