On May 12, 2021, ISDA responded to question four of a joint consultation paper by European Supervisory Authorities on taxonomy-related sustainability disclosures. ISDA recommends the inclusion of derivatives in the proposed key performance indicators (KPIs) for disclosing the extent to which investments are aligned with the taxonomy, but only where they are used to attain the environmental or social characteristics promoted by the financial product or the sustainable investment objective of the financial product. Additionally, ISDA suggests this approach should be applied consistently across all relevant calculation KPIs in respect of Non-Financial Reporting Directive entity reporting under article 8 of the Taxonomy Regulation, as differing interpretations could create investor confusion, result in fragmented outcomes and minimize the potential for evolution of risk management practices in the environmental, social and governance space going forward.
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