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Find all policy-related Invest Europe publications, such as member guides and briefings, consultation responses and position papers.

Invest Europe letter to the European Commission on SFDR RTS Image

Invest Europe letter to the European Commission on SFDR RTS

23 Feb 2021
Invest Europe

In this letter, Invest Europe expresses its concerns about the draft RTS under SFDR that were published by the European Supervisory Authorities (ESAs) on 4 February. In particular, we shed light on issues of potential overreach by the ESAs and/or divergence from the Level 1 legislation.

Download PDF 206.44 KB
Invest Europe Member Policy Call on SFDR Image

SFDR - Member Policy Call Presentation

15 Feb 2021
Invest Europe

Adinah Shackleton (Permira Advisers), Maaike van der Schoot (AlpInvest Partners) and Philip Bartram (Travers Smith) joined on 15 February a call to discuss the new SFDR rules in light of the forthcoming application date on 10 March 2021. In addition to the Known Unknowns, the call, whose recording is available on the Member Policy Calls' section of the website, also touched upon the recently published Regulatory Technical Standards (RTS) under SFDR.

Presentation on SFDR PDF 436.53 KB
Poll results PDF 111.85 KB
Industry response to ESMA consultation on CBDF marketing communications Image

Industry response to ESMA consultation on CBDF marketing communications

08 Feb 2021
Invest Europe-PAE

In this response we have expressed our concerns that ESMA has not taken proper account of the differences between the overwhelmingly institutional AIF industry and the retail fund industry, with respect to their respective distribution models. Concretely, ESMA has made some assumptions about the application of MiFID rules in the institutional marketplace which are not necessarily correct. This is particularly relevant in the context of: (i) the categorisation of AIF marketing as a MiFID investment service or activity; and (ii) the disclosure of information on past and expected future performance.

Download PDF 407.35 KB
Response to EC Consultation on Sustainable Corporate Governance Image

Response to EC Consultation on Sustainable Corporate Governance

08 Feb 2021
Invest Europe-PAE

In this consultation response, we have shared our views on the European Commission's Initiative on Sustainable Corporate Governance. Particular areas of focus were directors’ duty of care and due diligence duty. We stressed that while there are a number of good principles behind the idea put forward by the European Commission – such as holding directors accountable for creating real long-term value – it would create significant uncertainties and risks, if directors could be held to account by all different kinds of stakeholders, with no clear prioritisation on how they should weight all the different stakeholders’ interests.

Download PDF 407.72 KB
Invest Europe letter to the European Commission on SFDR application Image

Invest Europe letter to the European Commission on SFDR

04 Feb 2021
Invest Europe

Ahead of the fast approaching application date (10 March 2021), Invest Europe has been in contact with the European Commission to express its concerns about some of the grey areas around SFDR, including the scope of Article 8 and the public disclosures pursuant to Article 10 by private funds.

Download PDF 219.76 KB
Industry response to AIFMD consultation Image

Industry response to EC consultation on the AIFMD review

29 Jan 2021
Invest Europe-PAE

In this consultation response, Invest Europe reiterates that there is no need for a re-opening of the AIFMD because of a variety of factors. In addition, any changes to the AIFMD regime would lead to additional costs and (administrative) burden for the industry as members will need to re-adapt and get to grips with new requirements. If necessary, improvements to the AIFMD regime can be sought via Level 2 or 3 measures, or in the context of other legislative reviews.

General response PDF 1.05 MB
Delegation Paper PDF 197.22 KB
Invest Europe Non-Paper on SFDR Known Unknowns Image

Invest Europe Non-Paper on SFDR Known Unknowns

28 Jan 2021
Invest Europe

This non-paper touches upon the various areas of uncertainty ("known unknowns") that exist in the industry on the application of the SFDR rules.

Download PDF 191.45 KB
Response to EC Consultation on the ELTIF Review Image

Response to EC Consultation on the ELTIF Review

19 Jan 2021
Invest Europe-PAE

The European Long Term Investment Funds (ELTIF) framework, if not currently successful, has the potential to become a relevant tool in the future if it appropriately takes into consideration the needs of private equity managers. In this response we detail which changes would increase the take-up of this voluntary retail passport: broadened eligible assets, opening to fund-of-funds and requirements that are more tailored to the specificities of long-term, closed-ended funds.

Download PDF 625.94 KB
Response to EC Consultation on Risk Finance Guidelines Image

Response to EC Consultation on Risk Finance Guidelines

11 Jan 2021
Invest Europe-PAE

Over the years EU Risk Finance Guidelines allowed many start-ups and scale-ups to benefit from state aid support. While we note that the current regime is broadly appropriate, we suggest in this response a few changes that could be introduced to the Guidelines to make it easier for innovative companies to be eligible when owned by private equity.

Download PDF 298.06 KB
Response to EIOPA Request for comments on Solvency II review Image

Response to EIOPA Request for comments on Solvency II review

05 Nov 2020
Invest Europe-PAE

In this short response we express our concerns with several of the changes suggested by EIOPA to the criteria defining the ability of insurers to set up long-term equity portfolios (Art 171a of Delegated Regulation). These portfolios are subject to more appropriate capital charges for investments such as those made in private equity and venture capital funds.

Download PDF 323.79 KB
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Meet the team

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Martin Bresson Image

Martin Bresson

Public Affairs

Public Affairs Director

Erika Blanckaert Image

Erika Blanckaert

Public Affairs

Senior Public Affairs Manager

Xandra Hjort Image

Xandra Hjort

Public Affairs

Public Affairs Officer

Sofia Garrido Perez Image

Sofia Garrido Perez

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Public Affairs Officer

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Christophe Verboomen

Public Affairs

Public Affairs Manager

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