Positions & consultation responses
This targeted position paper sets out Invest Europe’s priorities for the SFDR 2.0 trilogues, focusing on the need to preserve the significant improvements secured in the compromise texts to date and to further adapt the product categorisation framework to the specificities of the PE/VC industry.
Invest Europe sets out priorities for a workable SFDR 2.0 for private markets
As negotiations on SFDR 2.0 move into trilogues, Invest Europe has set out its priorities for ensuring the new framework works effectively for private equity, venture capital and infrastructure. While welcoming progress towards a simpler and more proportionate regime, the paper highlights remaining barriers that could prevent private-market sustainability strategies from being adequately accommodated within the proposed framework.
Invest Europe calls for product categories that recognise active ownership and long-term engagement as drivers of real-world sustainability outcomes, preserve a sufficiently broad range of eligible investment strategies, and reflect the practical realities of closed-ended funds. Other priorities include workable arrangements for professional-investor-only funds, proportionate threshold and compliance requirements, a broad and market-relevant approach to impact investing, and relevant and proportionate sustainability reporting.
The aim is to ensure SFDR 2.0 supports transparency and informed investment decisions while enabling private capital to contribute effectively to Europe’s sustainability and transition objectives.
Response to EFRAG VSME consultation
Positions & consultation responses
10 May 2024
Response to European Commission Call for Evidence on Climate Resilience and Risk Management
Positions & consultation responses
03 Sep 2025
Invest Europe 40th Anniversary Interview: Cristina Fonseca, Indico Capital Partners
Videos
24 Jan 2024
Response to EFRAG’s Consultation on the European Sustainability Reporting Standards for Non-EU Undertakings (ESRS 40a)
Positions & consultation responses
22 Oct 2026
Response to the European Commission Calls for Evidence on the revised European Sustainability Reporting Standards (ESRS) and sustainability reporting standard for voluntary use
Positions & consultation responses
01 Jun 2026
Response to EFRAG's Consultation on the European Sustainability Reporting Standards (ESRS)
Positions & consultation responses
26 Sep 2025
Position Paper on the Sustainability Omnibus Proposal
Positions & consultation responses
28 Apr 2025
Response to the European Commission Consultation on the Taxonomy Delegated Acts as part of the Sustainability Omnibus
Positions & consultation responses
26 Mar 2025
Invest Europe letter to the Commission on forbearance measures during the Omnibus Package on Sustainability transition period
Positions & consultation responses
07 Mar 2025
Invest Europe letter to the Commission on the Omnibus Sustainability Package
Positions & consultation responses
25 Feb 2025
Invest Europe Response to EFRAG on Value Chain
Positions & consultation responses
02 Feb 2024
Position on CS3D 'subsidiary' definition
Positions & consultation responses
01 Dec 2022
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Invest Europe webinar: Value creation in the context of impact investing
Webinars
09 Sep 2025
Response to the European Commission Consultation to contribute to the Defence Omnibus Simplification Proposal
Positions & consultation responses
22 Apr 2025
Invest Europe Note on Article 6 of Corporate Sustainability Due Diligence Directive
Positions & consultation responses
02 Aug 2024
Feedback to the European Commission on CSRD proposal
Positions & consultation responses
14 Jul 2021
Industry response to ESAs consultation on SFDR/Taxonomy disclosures
Positions & consultation responses
12 May 2021
Feedback on the draft Delegated Regulation on the integration of sustainability in MiFID
Positions & consultation responses
06 Jul 2020
Response to ESMA Consultation on Sustainability in MiFID II
Positions & consultation responses
19 Feb 2019
Response to Commission Consultation on Long-Term and Sustainable Investment
Positions & consultation responses
25 Mar 2016
Over one third of European private equity, venture capital firms have environmental management systems in place
Press releases
26 Mar 2026