Invest Eurpe-PAE

Response to ESMA Consultation on Sustainability in MiFID II

Positions & consultation responses

19 Feb 2019

In this response, we express our support for ESMA’s proposed high-level principles-based approach, avoiding overly prescriptive rules, which could increase the risk of regulatory arbitrage. We also support ESMA’s recognition that any changes introduced should be applied by firms with the proportionality principle in mind, taking into account the size, nature, scale and complexity of their activities.