The European ESG Template (EET) was first released in April 2022 to help financial market participants to comply with European sustainable finance legislation such as SFDR, IDD or MiFiD. Since its conception, two further versions have been released by FinDatEx in October 2022 and January 2023 to adapt to changes in regulation. Any notable changes in these versions 1.1 and 1.1.1 are detailed in the article below, along with a brief summary of the EET and its importance for financial market actors.
The European ESG Template is a project developed by FinDatEx to comply with ESMA and FCA regulations, such as the SFDR, MiFiD and IDD, which compel greater market transparency for sustainable investments. It is a standardised template for financial services stakeholders which aims to simplify the process of exchanging ESG data between participants, making it easier to conform to legislative requirements.
The template contains upwards of 600 machine-readable ESG fields such as ‘Greenhouse Gas Emissions’ or ‘Hazardous Waste’ indicators which allow participants to easily justify a fund’s ESG characteristics to potential investors. While participation with the EET is not compulsory, market pressure to conform to standards set by ESMA and FCA will make it very difficult to sell a product without the template being available.
The original version was released in April 2022, with the intention being to update the fields over time to adapt to new regulation from legislative bodies. So far, new versions 1.1 and 1.1.1 have been released with changes to accommodate for the latest developments to the SFDR, as will be discussed in more detail below. Going forward the template will be updated on a yearly basis.
The EET V.1.1 was released on the 24th October 2022 in order to incorporate any information required under the updated Regulatory Technical Standards (RTS) and SFDR Taxonomy which come into effect from 1st January 2023. There have been no major structural amendments to the template, with changes being limited to classification changes, corrections and a limited number of new fields, as described below.
- Classification changes
The original EET template consists of around 600 pre-defined fields which are classified as either ‘Mandatory’, ‘Conditional’ or ‘Optional’. These fields are designed to adapt over time in line with legislation, so what may currently be ‘Optional’ could be ‘Mandatory’ in the future. These classification alterations constitute the bulk of the changes associated with v1.1, as numerous fields become mandatory or conditional where they were once optional in order to comply with the latest legislation
Examples include the ‘Product Disclosure’ fields which are now ‘Conditional’ having previously been ‘Optional’. Any amended fields are highlighted in yellow on the v1.1 template, which can be downloaded from the FinDatEx website.
Most of the other changes in V1.1 are amendments to field definitions. Some descriptions have been updated to provide greater clarity to end users and to better illustrate their purpose. Similarly, any punctuation or grammatical errors have been corrected.
Example changes include amendments to the naming for ‘ESG thematic investing description’ fields, and definition updates for some ‘Product Disclosure’ fields. Again, any amended fields are highlighted in yellow in the V1.1 Template, with changes marked in red.
- Field Additions and Removals
Eight new fields have been added, with six in relation to structured products, one for ‘Total AUM’ and another regarding the relevance of sustainability risks. These can be found at the bottom of the template under ‘Supplementary Fields’. Additionally, a small number of fields have been removed, including field 103, the ‘Principle Adverse Indicator’.
EET V1.1.1 – Natural gas and nuclear power inclusion
A further updated template was released on 18th January 2023 which incorporates the v1.1 amendments, along with several further minimal changes. It aims to encompass the latest SFDR developments such as Gas and Nuclear activity inclusion.
26 new fields have been added in relation to Gas and Nuclear, and can be found at the bottom of the template on the FinDatEx website, as before. Additionally, a new data field has been added in relation to PAI information.
Which template to use?
While FinDatEx recommends that v1.1.1 should be used immediately, there is a transition period in place until the 30th April 2023. Until that time, version 1.0 and 1.1 can be used in parallel. However, after 30th April 2023, V1.1.1 should be the only version of the EET template in use.
The EET template will be updated on an annual basis to cover any periodic disclosures and updates to financial legislation. It is expected that the first update should occur in April 2023, as periodic annexes for financial products have a year-end on the 31st December.
Given a greater focus by ESMA and the FCA on sustainability and transparency regarding ESG investments, tools like the EET will be an increasingly central concern. As ESG regulation becomes more comprehensive, the EET will require more detailed adaption, and its inclusion will be more essential to the processes and due diligence of both product vendors and investors.
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