Consultations and letters

UK

December 2023

PRI contribution to the Transition Plan Taskforce (TPT) consultation on sector specific transition plan guidance for asset owners and asset managers.

The PRI welcomes the sector-specific guidance for asset owners and asset managers. The guidance is comprehensive, and we support the recommendation that Asset Owners and Asset Managers “take a strategic and rounded approach to transition planning”. We encourage strengthening the connection between the strategic ambition of transition plans with achieving real economy outcomes, and including language that provides clarity on fiduciary duties.

See contribution

EU

December 2023

PRI response to the Targeted consultation on the implementation of the Sustainable Finance Disclosure Regulation (SFDR)

The PRI supports the development of minimum sustainability criteria to better distinguish financial product categories under SFDR, as well as a baseline of sustainability disclosures for all products, regardless of their sustainability claims. This would contribute to creating a level playing field regarding sustainability reporting obligations and increase comparability across financial products in the EU.

See response

Australia

December 2023

PRI response to the Australian Treasury’s consultation on Australia’s Sustainable Finance Strategy

The PRI welcomes the Australian Government’s publication of the Australian Sustainable Finance Strategy. The collection of measures identified within the Strategy represent an important step forward in providing the frameworks, information and tools needed by investors to better integrate sustainability-related risks and impacts into their activities, and to contribute to Australia’s net zero transition.

See response

EU

November 2023

PRI statement on appropriate and practicable inclusion of the financial sector in the CSDDD

In advance of the next trilogue discussion between European Commission, Parliament and Council, the PRI has published a final statement calling for appropriate and practicable inclusion of the financial sector in the Corporate Sustainability Due Diligence Directive. This statement is based on previous position papers and recent conversations with signatories. It will be sent to all relevant policymakers in negotiations. If you have any feedback or want to learn more, email [email protected].

See statement

Global

October 2023

UN Working Group on Business and Human Rights call for input on Investors, ESG and Human Rights

The PRI welcomes the intention from the UN Working Group to provide practical guidance to states, businesses, financial institutions, civil society, and other stakeholders on how to align better ESG approaches with the UNGPs in the context of financial products and services. We recommended that the final report of the Working Group references: - The necessity to fully integrate social issues into the economic transition, including through sustainable finance and real economy policy regulation. - The need for policy reform to enable the improvement of the sustainability outcomes of investments. - The systemic relevance of human rights and social issues, including growing inequalities.

See response

US

October 2023

PRI letter to New York Governor supporting adoption of a human capital management disclosure bill

PRI submitted a letter to Governor Kathy Hochul of New York, supporting the adoption of Assembly Bill A5981. If signed, the bill would require companies operating in the state of New York to file their EEO-1 reports with the NY Secretary of State. Companies' data on the race, gender, and ethnicity of employees would then be made publicly available. By requiring companies to file their EEO-1 data for public release, New York can support investor efforts to identify and address HCM-related issues across their portfolios. Certain companies are already required to report this information annually to the Equal Employment Opportunity Commission, and as such, sharing this information with the State of New York—and with investors—requires no additional effort.

See letter

Japan

October 2023

PRI response to JFSA’s invitation for public comments regarding the Draft Basic Guidelines on Impact Investment

The PRI supports the JFSA’s efforts to integrate sustainability impacts across the financial sector. PRI recommends that the JFSA strengthen these efforts by considering policy measures that can more holistically encompass the various approaches it can take to mainstream investing for sustainability impact.

See response in English and Japanese

Australia

September 2023

Joint Investor Statement on Corporate climate transition plans

The PRI, together with IGCC and CDP, released a joint statement calling on the Federal Government to establish a clear framework for developing and disclosing transition plans which supports a whole of economy just transition aligned with limiting global temperatures to 1.5°C.

Statement

Canada

September 2023

The Canadian Securities Administrators (CSA) consulted on Proposed Amendments to Form 58-101F1 Corporate Governance Disclosure of National Instrument 58-101 Disclosure of Corporate Governance Practices and Proposed Changes to National Policy 58-201 Corporate Governance Guidelines

The PRI’s response supports the CSA’s intention to mandate corporate governance disclosure requirements of non-venture issuers to include aspects of diversity beyond the representation of women on boards and in executive officer positions, and makes a series of recommendations, including alignment with DEI metrics in the CBCA, and the consolidation and streamlining of the various corporate disclosure forms to develop a wider, holistic corporate sustainability disclosure regime built upon the formal adoption of ISSB Standards S1 and S2.

See response

EU

September 2023

PRI letter to the European Parliament, the European Commission and the Council of the European Union

The PRI calls on the EU institutions to ensure the inclusion of sustainability elements in the final text of the Solvency II directive.

See letter

UK

September 2023

PRI response to the Financial Reporting Council (FRC) over proposed changes to the UK Corporate Governance Code

The PRI welcomes the proposed changes to the UK Corporate Governance Code. The PRI is particularly supportive of revisions seeking to prompt more outcomes-based reporting, increased transparency on director appointments and the inclusion of narrative (sustainability) reporting within the remit of audit committees. We encourage the FRC to introduce provisions on the disclosure of sustainability related skills and experience of board members and governance arrangements for the oversight of sustainability matters.

See reponse

Australia

September 2023

PRI and Australian peak bodies responded to ISSB agenda priorities

The PRI, together with several of Australia’s peak bodies, highlighted the importance of the ISSB leading and working with jurisdictions to build capacity and support the effective implementation of IFRS S1 and S2. The submission further encouraged the ISSB to take a collaborative and coordinated approach with existing and developing frameworks in its future work plan.

See reponse

UK

August 2023

PRI response to the Department for Business and Trade (DBT) and the Financial Reporting Council (FRC) review into non-financial reporting requirements

The PRI welcomes this review as an opportunity for the DBT and FRC to increase the consistency, reliability, and comparability of non-financial corporate reporting. We make recommendations on reporting criteria, ISSB implementation, and highlight the value of non-financial reporting.

See reponse

EU

July 2023

PRI reaction statement and quote on adoption of ESRS 1 and ESRS 2

PRI welcomes this delegated act as an important step towards investors having access to the data they need to assess sustainability risks, opportunities and impacts of investee companies. Through improved transparency of materiality assessments, investors will be able to keep a watchful eye on investee reporting and will expect comprehensive disclosures based on accurate and science-based materiality assessments. However, to guarantee investor’s access to the data they need to comply with their own mandatory reporting obligations and allocate capital in line with sustainability goals, we urge the European Commission to commit to making key climate disclosure indicators, and environmental and social indicators relevant to SFDR mandatory to disclose in the first review of this delegated act.

See reponse

HK SAR

July 2023

HKEX consultation paper on enhancement of climate-related disclosures under the ESG framework

The PRI strongly welcome the proposals of HKEX, the requirements under consultation are closely aligned with exposure draft IFRS S2 Climate-related Disclosures and ISSB decisions related to this Standard. Our response welcomes areas of alignment with the ISSB’s proposals, and highlights where we believe further alignment is needed. We also recognize investors' data needs beyond climate and on wider sustainability issues.

See reponse

EU

July 2023

The European Supervisory Agencies have published for consultation some targeted changes to the SFDR technical standards (RTS). These changes relate to the disclosures of principal adverse impacts (and related indicators) and disclosures at financial product level.

Whilst PRI supports the proposed expanded social PAI indicators and climate target-setting proposals, policymakers will need to maintain consistency with the final ESRS standards as adopted by the European Commission to ensure investors have sufficient data to produce meaningful reports as per their SFDR obligations.

See response

Australia

June 2023

The PRI responded to the consultation document issued by the Climate Change Authority on its advice for the next Australian Nationally Determine Contribution among other matters.

The PRI-Coordinated Collaborative Sovereign Engagement on Climate Change recommends the benefits of an accelerated, orderly and Paris-aligned NDC for Australia’s sovereign climate risk profile, economic competitiveness and future cost of capital should be reflected by the Authority in its final advice to the Federal Government.

See response

Global

June 2023

PRI response to the TNFD’s consultation on the fourth (v0.4) iteration of its beta framework.

PRI strongly welcomes the latest version of the TNFD disclosure recommendations and the supporting assessment LEAP approach. PRI further formulates five recommendations related to materiality, priority locations, core global metrics, financial core metrics, and guidance.

See response

Global

May 2023

The PRI submitted a response to the UN Working Group on Business and Human Rights' call for inputs: Extractive sector, just transition and human rights.

The PRI welcomes the Working Group’s intention to provide the UN General Assembly with further information to ensure that the economic transition is just and takes into consideration the basic rights of all individuals, including the wide range of stakeholders involved in the mining sector value chain.

See response

EU

May 2023

Joint Business Networks’ Letter to the European Parliament on supporting an ambitious Nature Restoration Law.

The PRI, together with other leading Business Networks, call for a robust, ambitious, and coherent outcome from the EU Nature Restoration Law negotiations. This entails policy that supports the EU Green Deal’s nature and climate ambitions, and its alignment with the Paris Agreement and CBD COP15 Kunming-Montreal Agreement on biodiversity.

See letter

US

May 2023

PRI Response to the Financial Accounting Standards Board (FASB) proposed accounting standards update for income taxes

The PRI supports the proposed changes to Topic 740 of the FASB Accounting Standards Codification® on requiring more granular and specific information regarding rate reconciliation and income taxes paid. We further recommend the FASB considers additional amendments in the future to meet the evolving needs of investors around income tax disclosures. The benefits to investors would be greatly enhanced if these proposed changes were to be accompanied by disclosures on key jurisdiction-level information such as revenues and operating results on a similar level of disaggregation.

See reponse

Australia

April 2023

PRI response to the Treasury’s consultation on public country-by-country reporting.

PRI response to the Treasury’s consultation on public country-by-country reporting PRI response: PRI strongly welcomes the Treasury’s exposed draft on public reporting of country-by-country (CBC) information. Australia would take a leadership position by becoming the first jurisdiction to mandate the public disclosure of full CBC information. The Australian Treasury’s proposed disclosure regime will have a significant impact on investors’ ability to assess the risk profile of an entity’s tax affairs and incorporate tax issues in their decision-making processes.

See letter

Australia

March 2023

The PRI responded to Treasury’s consultation on legislating the objective of superannuation

The PRI welcomes the Australian Government’s proposal to legislate an objective for the superannuation system, which includes the concept of sustainability. However, the PRI highlights that the proposed definition of “sustainable” is relatively narrow and potentially misaligned with existing duties. Accordingly, the PRI recommended the definition of sustainable better take into account the superannuation system’s reliance on a strong economy and its role in supporting the economy’s stability, as well as the environmental and social systems the economy relies upon.

See response

Australia

March 2023

Together with other industry associations and leading financial institutions, the PRI issued a joint finance industry statement welcoming the Australian Government’s proposal to reform the Safeguard Mechanism.

While welcoming the proposals, the statement notes that the emissions reductions required under the Safeguard Mechanism are not yet aligned with actions needed to limit global warming to 1.5 degrees. The statement outlines specific measures to bolster and complement the mechanism and to ensure it would be a floor, not a ceiling, to facilities’ decarbonisation measures.

See statement

Australia

March 2023

The PRI responded to APRA’s consultation on draft investment governance guidance for superannuation funds SPG 530  

The PRI welcomes APRA’s proposals to update SPG 530 and clarify its expectations about how RSE licensees address ESG factors. Although the proposed amendments provide a much-needed update to the previous version, additional guidance is required to comprehensively align with current market practice and support RSE licensees to discharge their legal duties. The PRI therefore recommends that SPG 530 specifically references the need for RSE licensees to assess and mitigate system-level ESG risks and provide guidance on the investment and stewardship activities needed to do so, including through the intentional pursuit of sustainability-related outcomes.

See response

UK

February 2023

PRI response to UK Transition Plans Taskforce (TPT) Consultation Survey

The PRI welcomes the work of the Transition Plan Taskforce (TPT) to drive robust, credible, and interoperable transition plans and disclosure frameworks from finance and real economy actors. The PRI agrees with the TPT’s approach in building and aligning to the International Sustainability Standards Board (ISSB) Climate Exposure Draft, the Task Force on Climate-Related Financial Disclosures (TCFD) framework, and recommendations from the High-Level Expert Group (UN HLEG) on the Net Zero Commitments.

See response

EU

February 2023

PRI response to ESMA consultation on ESG-related fund names

The PRI is supportive of ESMA’s efforts to ensure that funds’ names reflect their investments’ characteristics and objectives. We encourage EU policymakers to clarify how key underlying concepts (particularly sustainable investment) should be applied in practice, before setting quantitative thresholds. The proposals could also be made more relevant to different investment strategies and accurately reflect the tools investors have to create change (particularly stewardship).

See response

Global

February 2023

PRI response to IOSCO consultation on compliance and voluntary carbon markets.

The PRI Executive welcomes IOSCO’s work to develop sound carbon markets that are well-equipped to achieve their core environmental objectives. Carbon markets are a necessary tool to achieve net-zero and IOSCO’s work in this area signals their growing relevance. Although carbon markets have proliferated in recent years, there is still work to be done to unlock their full potential.

See response

Global

February 2023

PRI's response to the OECD consultation on the targeted update of the Guidelines for Multinational Enterprises.

The PRI welcomes the proposed update to the OECD MNE Guidelines, including: the expansion of the scope of due diligence from a focus on supply chains to encompass wider business relationships; the recognition that “an enterprise’s relationship to adverse impacts is not static”, and the specification that investee companies are part of a company’s business partners; and the expansion of the provisions relating to environmental issues to require risk-based environmental due diligence, including the recognition of the need to adopt a just transition lens in assessing the potential or actual adverse impacts to workers, communities, and consumers. Areas for improvement include expressly mentioning the role of institutional investors in supporting the implementation of responsible business conduct, strengthening the guidelines on ensuring transparency and integrity in lobbying activities by encouraging enterprises to report further details on their practices, and acknowledging the systemic issue of tax avoidance and profit-shifting and the proactive role that multinationals should play in tackling it.

See response

Japan

January 2023

PRI response to JFSA’s invitation for public comments regarding proposed partial amendments to the comprehensive supervisory guidelines for financial instruments business operators, etc. regarding ESG investment trusts

The PRI supports the JFSA’s efforts to address concerns of “greenwashing” among publicly offered investment trust funds with express ESG claims. PRI recommends that the JFSA provide clearer explanations on key concepts and stay aware of international developments in this area.

See response in English and Japanese

EU

January 2023

Joint Business and Investor Letter supporting an ambitious and robust Energy Performance of Buildings Directive (EPBD) ahead of the ITRE committee vote on 9 February 2023.

The PRI, together with the Corporate Leaders Group (CLG), Climate Group, the Institutional Investors Group on Climate Change (IIGCC), and several other business and investor groups, encourages the Members of the European Parliament Committee on Industry, Research and Energy (ITRE) to take an ambitious and robust position on the Energy Performance of Buildings Directive in its committee vote on 9 February 2023.
To provide a clear enabling policy environment for private sector investment in buildings’ energy efficiency and deep retrofits, the PRI supports minimum energy performance standards (MEPS) for both residential and commercial buildings as a key element in the EPBD revision, as well as harmonising the Energy Performance Certificate system to ease planning and measuring progress across the EU building stock.

See letter

EU

January 2023

PRI response to ESA consultation on greenwashing in the financial sector.

The PRI has responded to the European Supervisory Authorities (ESA) consultation on greenwashing in the financial sector. Supporting the ESAs proposed features of greenwashing, we encourage EU policymakers to complete existing standards and policies to further promote clarity, transparency and accountability in the EU framework.

See statement

Australia

December 2022

The PRI responded to Treasury’s consultation on empowering the AASB to deliver sustainability standards.

The PRI supports the Australian Government’s intention to implement sustainability standards and ensure large business are transparent and accountable to investors. The PRI encourages the Government to base these standards on the ISSB’s final sustainability and climate-related financial disclosure standards and implement additional legislation to require mandatory disclosures. The PRI further recommends that any entity implementing the standards be appropriately governed and resourced.

See response

EU

November 2022

PRI statement on draft European Sustainability Reporting Standards

This PRI statement welcomes the latest draft European Sustainability Reporting Standards (ESRS) by the European Financial Reporting Advisory Group (EFRAG) and sets out five priority elements that co-legislators and the European Commission should retain within the final standards.

See statement

UK

November 2022

The PRI provides comments on a consultation from the Department for Levelling Up, Housing and Communities (DLUHC). This consultation seeks views on proposals to require administering authorities of the Local Government Pension Scheme (LGPS) to have effective governance, strategy, risk management and accompanying metrics and targets for the assessment and management of climate risks and opportunities

In our response, the PRI welcomes the proposal from DLUHC to require LGPS schemes to assess, manage and disclose climate-related risks in line with the recommendations of the Taskforce on Climate-related Financial Disclosures (TCFD). In particular we welcome proposals to align new requirements for LGPS AAs with existing requirements for occupational pension schemes, as set out by the DWP earlier this year.

See response

EU

November 2022

Joint investor statement of support for an ambitious and effective European directive on corporate sustainability due diligence (CSDD)

The PRI, Eurosif, Investor Alliance for Human Rights and 142 undersigned signatories (representing approximately 1.5 trillion USD in AUM) welcome the European Commission’s CSDD proposal. This statement raises 5 key recommendations to create an ambitious and effective directive, which works for investors, complements the existing EU legislation and is aligned with international standards including the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines for Multinational Enterprises.

See statement

Australia

November 2022

The PRI responded to the review by Attorney-General’s department of the Modern Slavery Act 2018 (Cth).

The PRI commends the Australian Government for its commitment to improve the Act and highlights concerns with the modern slavery statements already submitted. Accordingly, the PRI recommends the Minister and departments undertake a quality review. Additionally, the PRI recommends the Act include an express requirement for entities to carry out a due diligence process.

See response

Australia

November 2022

The PRI responded to APRA’s consultation on its prudential standards for strategic planning and member outcomes – SPS 515

The PRI recommends that SPS 515 should be updated to ensure RSE licensees are explicitly required to consider system-level risks when setting strategic objectives and, along with SPG 515, enhanced to support RSE licensees to assess members’ sustainability objectives. Further guidance should also be provided on how RSE licensees can set and pursue goals to shape real-world sustainability outcomes.

See response

UK

October 2022

PRI's response to a call for evidence by BEIS on the government's approach to delivering its net zero target.

The PRI welcomes the opportunity to respond and makes recommendations showcasing the ability of net zero targets to deliver maximum economic growth and investment, and to support UK energy security and affordability.

See response

Global

October 2022

PRI response to review of the G20/OECD principles of corporate governance

The G20/OECD Principles are being reviewed in light of recent evolutions in capital markets and corporate governance policies and practices. PRI welcomes many aspects of the reviewed Principles and makes recommendations on executive remuneration, whistleblowing, the responsibilities of the board, DEI, stewardship, investor collaboration and sustainability reporting.

See response

Canada

September 2022

PRI response of the Office of the Superintendent of Financial Institutions (OSFI) on Draft Guideline B-15: Climate Risk Management

The PRI welcomes OFSI’s signal to the Canadian and international markets in aligning the B-15 guideline with the most recent TCFD guidance and referencing disclosure against ISSB disclosures. The PRI makes recommendations on greater coordination with ISSB, CSSB, and CSA, as well as ensuring that disclosures are included in financial statements, transition plans aligned with targets, and voluntary scenario analysis.

See response

EU

September 2022

Joint letter from PRI, CDP, IIGCC, and Eurosif on Fit for 55 trilogues

The CEOs of PRI, CDP, and IIGCC – under the auspices of The Investor Agenda – in collaboration with Eurosif published an open letter to Frans Timmermans, Pascal Canfin, and Jaroslav Zajíček regarding the trilogue negotiations on a number of EU “Fit for 55” files. The letter emphasises the need to swiftly implement an ambitious Fit for 55 package that will save energy, accelerate the expansion of renewables, catalyse low-carbon innovation, and mobilise private capital towards sustainable outcomes, all while ensuring a just transition.

See letter

UK

September 2022

Joint letter from PRI, IIGCC, and UKSIF: CEOs of leading investor groups call on new government to uphold net zero ambition

The CEOs of PRI, IIGCC, UKSIF and 8 leading UK investors published an open letter to the UK Prime Minister and officials outlining the case for upholding net zero ambition. The PRI and investor signatories emphasises the need for a clear delivery plan for the transition of the real economy and financial services, with credible sectoral roadmaps underpinned by the near-term policies, actions and milestones needed to shift financial flows towards net zero.

See letter

South Africa

September 2022

PRI response to the South African Reserve Bank’s draft national Climate Risk Scenarios

PRI warmly welcomes the South African Reserve Bank’s important work on developing regional Climate Risk Scenarios and supports its objective to build capacity across the financial sector to better mitigate the financial risks and other impacts on South Africa’s economy. The importance for climate risk modelling focused on local conditions is essential for financial markets to more accurately assess and price in risks. This will enable investors to allocate capital more efficiently and to play their part in helping to achieve the Paris Agreement.

See response

Japan

September 2022

PRI response to JFSA’s invitation for public comments regarding the Draft Code of Conduct for ESG Evaluation and Data Providers

PRI welcomes JFSA's proposal to introduce a Draft Code of Conduct for ESG Evaluation and Data Providers. PRI recommends that JFSA implements appropriate accountability and enforcement mechanisms, commits to periodic reviews and revisions of the code, and provides clarity on key concepts and the extent of the overall scope of applicability to ensure alignment and coherence among the market.

See response in English and Japanese

Australia

September 2022

PRI response to Treasury's consultation on strengthening Australia’s multinational tax avoidance and tax transparency rules

The PRI welcomes the Treasury’s intention to address the tax avoidance practices of multinational enterprises (MNEs) and improve transparency through better public reporting of MNEs’ tax information. The PRI recommends that reporting entities be required to report relevant tax-related information for all countries of operation, not just a limited set of jurisdictions; and that reporting standards should align as much as possible with disclosure 207-4 (Country-by-country reporting) of the GRI 207 standard.

See response

Global

August 2022

Joint PRI, IFAC and WBCSD statement calling for alignment between sustainability reporting standard setters and frameworks

The PRI, IFAC, WBCSD and undersigned organisations call on major standard-setting efforts to align and support a global baseline for sustainability-related information – by aligning on key concepts, terminologies and metrics upon which disclosure requirements are built.

See statement

US

August 2022

PRI comment to the SEC on Investment Company Names

The PRI supports the SEC’s proposed rule and its efforts to ensure that funds’ names reflect their investments in the fund and address materially misleading or deceptive fund names. The PRI recommends that the SEC Define the term "characteristics" and clarify the expectations for funds on how to determine an investment focus with such characteristics.

See response

EU

August 2022

PRI responses to EFRAG consultations on Exposure Draft European Sustainability Reporting Standards

The PRI welcomes the publication of Exposure Draft European Sustainability Reporting Standards (ESRS) by the European Financial Advisory Group (EFRAG) and is broadly supportive of their content. Our recommendations seek to ensure that reporting under the ESRS meets the information needs of responsible investors.

See response

Australia

July 2022

PRI response to the AASB’s request for comment on the ISSB’s Exposure Drafts IFRS S1 and S2

The PRI strongly supports the development of a global baseline of sustainability disclosures and encourages the AASB to engage closely with the ISSB in the development of IFRS S1 and S2. The PRI recommends that the Federal Government introduce legislation that requires mandatory disclosure of sustainability information by listed and large propriety companies by 2024, and authorises the AASB to issue standards for such sustainability information. Those standards should be based on the final IFRS standards as a minimum baseline.

See response

UK

June 2022

The PRI responded to a call for evidence by HM Government to support the update to the Green Finance Strategy. The call for evidence seeks views around four objectives; capturing the opportunity of green finance; mobilising finance for the UK’s energy security, climate and environmental objectives; greening the financial system; and leading internationally.

The PRI are supportive of plans to update the Green Finance Strategy and welcome the opportunity to respond to this call for evidence. In our response, we outline some high level recommendations around maintaining ambition for reporting and disclosure frameworks such as SDR and the UK Green Taxonomy, as well as ensuring consistent messaging between policymakers, both within the UK and internationally. We also call for a shift towards a regulatory environment that permits and enables sustainability outcomes-focused investment.

See response

UK

June 2022

Joint open letter from IIGCC, the PRI and UKSIF: Leading investor groups call for natural gas to be excluded from the UK’s ‘green taxonomy’

The CEOs of IIGCC, PRI and UKSIF published an open letter to the UK Prime Minister outlining the case against including natural gas in the UK’s taxonomy. The PRI and other signatories emphasise the need for a credible, science-based taxonomy that is fully aligned with the UK’s ambitious net zero strategy. Gas may be necessary as a ‘bridge’ during the transition, but it should not be labelled as ‘green’.

See letter

EU

June 2022

PRI response to the European Commission consultation on ESG ratings and incorporation of ESG in credit ratings.

The PRI welcomes increased attention by the European Commission to the market for ESG ratings and data products and the providers of these products, given the important role these products play in investment processes. PRI recommends the Commission focuses regulatory action on improving transparency of methodologies and processes, and ensuring providers have appropriate governance processes in place.

See response

Global

May 2022

Race to zero 2022 criteria consultation

This consultation has been designed by the High-Level Climate Champions, the UNFCCC and the Expert Peer Review Group for the Race to Zero.

See response

US

May 2022

PRI comment to the Department of Labor on protecting American retirement savers from climate-related risks

The PRI welcomes the Department of Labor’s consultation as the Department is duty-bound to take active steps to address potential impacts of climate-related financial risk to American savers.

See response

US

April 2022

PRI template comment for signatories to respond to the SEC’s proposed climate disclosure rule

The PRI encourages its signatories to submit comments to the SEC on the proposed climate disclosure rule. This template serves as a starting point for signatories looking to prepare their own comment letters.

See letter

EU

April 2022

Joint PRI and Eurosif letter on necessity for net-zero disclosures in CSRD

The PRI and Eurosif have written to European Parliament, Commission and Council of the EU, on behalf of the sustainable investment industry, to emphasise the need for a CSRD framework that promotes meaningful transition efforts on the part of companies and provides investors with effective tools to steer capital towards sustainability leading companies. It is crucial that, at the end of the trilogue negotiations, CSRD mandates companies to prepare transition plans and disclose the scenarios used for these plans as well as the key assumptions underpinning these scenarios.

See letter

US

March 2022

The PRI responded to Municipal Securities Rulemaking Board’s (MSRB) request for info on ESG practices

The PRI is encouraged by MSRB’s request for information as it considers how best to incorporate ESG-related information in its regulatory and oversight duties. PRI recommended MSRB work to encourage standard ESG disclosure and relevant information across the municipal securities market to provide investors with consistent, comparable information.

See response

EU

March 2022

The PRI responded to the European Securities Market Authority (ESMA) call for evidence on market characteristics for ESG rating providers in the EU.

The PRI welcomes increased attention by regulators such as ESMA to the market for ESG ratings and data products and the providers of these products, given the important role these products play in investment processes. PRI recommends regulators focus on improving transparency of methodologies and processes, and ensuring providers have appropriate governance processes in place.

See response

US

March 2022

PRI Comment on Pay vs. Performance

The PRI submitted a comment to the SEC in response to the reopening of the comment period for Pay vs. Performance. The PRI supports the disclosure of a company-selected measure as well as the list of the five most important performance measures, as these additions would allow registrants the flexibility to show whether ESG performance measures significantly impact executive pay.

See response

UK

March 2022

The PRI provides comments on a consultation from the Department for Business, Energy & Industrial Strategy (BEIS) on proposals to design a climate compatibility checkpoint for future oil and gas licensing in the UK Continental Shelf.

In our response, the PRI welcomes the proposal to apply a climate checkpoint to North Sea oil and gas production and encourages the government to set stringent and ambitious tests to the licensing of oil and gas exploration in the UK.

See response

Canada

February 2022

PRI response to the Canadian Securities Administrators draft regulation 51-107 respecting disclosure of climate-related matters

The PRI encourages the CSA to mandate disclosure of Scopes 1 and 2 and most relevant Scope 3 emissions categories using the GHG Protocol, as well as scenario analysis. The CSA should aim to phase in the holistic implementation of the 11 TCFD recommendations, reflecting the 2021 Guidance on Metrics, Targets and Transition Plans.

See response
See sign-on letter in English
Voir la lettre d’appui en Français

China and EU

January 2022

International Platform on Sustainable Finance (IPSF) consultation on Common Ground Taxonomy (CGT)

The PRI recognises that taxonomies are a key tool for redirecting financial flows towards economic activities that meet robust sustainability standards and are aligned with high-level policy commitments, therefore, the CGT could be a useful tool to increase the interoperability of taxonomies, on the condition that clarifications and improvements are made regarding its purpose, science-basis, methodology and presentation of criteria.

See response

UK

January 2022

The PRI respond to a consultation from the FCA that seeks initial views on new sustainability disclosure requirements (SDR) for asset managers and FCA-regulated asset owners, as well as a new classification and labelling system for sustainable investment products.

The PRI support the FCA’s proposed approach on the design principles, coherence and inoperability, product labels and disclosure layers, and classification and labelling for a full range of investment products, but recommends that the FCA revise the potential categories of the classification and labelling system, and reconsider how best to draw on the EU Sustainable Finance Disclosure Regulation (SFDR).

See response

China

January 2022

China consultation on regulations of insurance asset management companies

To ensure that IAMCs are appropriately managing ESG related risks and opportunities as a part of their obligations to clients, the PRI recommends that the proposed regulation should make clear that IAMCs must consider ESG factors in their corporate governance, risk management, investment activities, stewardship, and disclosure practices.

See response in English and Chinese