On September 1, ISDA submitted a response to the European Commission’s consultation on its proposal for the regulation of environmental, social and governance (ESG) ratings. ISDA supports a regulatory framework for ESG ratings based on recommendations set out in a report on ESG ratings and data product providers by the International Organization of Securities Commissions, with a view to enhance transparency and integrity of the market. In the response, ISDA suggests that further clarification is needed on scope and definitions – in particular, the definition of an ESG rating, as well as authorization procedures and the regulation of third-country ESG ratings.