Publications
& Policy

"The most comprehensive data-driven analysis of European technology"

Aimed at firms that are already quite advanced in their ESG journeys, Invest Europe's second Climate Change Guide "Engaging Portfolio Companies" intends to provide practical support and advice to members on how to engage and communicate with their portfolio companies on climate change matters. 

In this letter to the European Commission, Invest Europe expresses the industry's ongoing key concerns about SFDR and its interaction with the Taxonomy Regulation. In particular, we encourage the Commission to address and resolve some of the remaining uncertainties through the revisions which we understand may be contemplated to the draft SFDR Regulatory Technical Standards, due to come into effect on 1 July 2022.

Invest Europe, in partnership with the European Investment Fund (EIF), published ‘The VC Factor - Pandemic Edition’, a new report illustrating European venture capital’s continued strong support for innovative and fast-growing start-ups in the immediate aftermath of the COVID-19 pandemic in 2020.

In our response to the survey we identify the current challenges and possible solutions to foster innovation. These solutions, which cover 4 different areas, include the identification and removal of regulatory burdens, the creation of a critical mass for VC in Europe through public support and the creation of the right conditions to strengthen patient capital in Europe, amongst others. We believe the implementation of these actions at pan-European level would contribute to strengthen the European innovation ecosystem for the ultimate benefit of European citizens and economy.

In this response, we explain a typical PE structure and the commercial purpose of each of the entities, and why these entities should not fall under the definition of shell entities. We believe that the commercial purpose of an entity is a good indicator for determining whether it is a shell entity or not, and must thus be taken into account in the definition.

“According to a diversity study conducted by the Finnish Venture Capital Association and KPMG now for the second time, the share of women on the boards of companies owned by private equity and venture capital investors has decreased, while the share of women in top management has increased.”

This position paper describes the relationship between private equity and retail clients - suggesting key policy changes that could be introduced to make sure large sophisticated investors and small private ones are able to access the asset class directly or indirectly depending on their risk characteristics.

The Markets in Financial Instruments legislation (split into the MiFID Directive and the MiFIR Regulation) covers both business conduct and organisational requirements for investment firms, as well as authorisation requirements for public markets and rules on the admission of financial instruments to trading.

In this response we argue that changes should be made to the definition of a "professional investor upon request" to better acknowledge the features of long-term & sophisticated investors in asset classes such as private equity. We also describe to the European Commission our concerns with the current retail disclosure documents, which are too standardised to give investors an appropriate idea of the real risk and benefits of long-term investments.

"Investors seeking to gain initial exposure to private investments should actively consider secondaries, rather than funds-of-funds, as the very first step to constructing a long-term private equity portfolio"

This long awaited official Guidance from the European Commission clarifies the application of the Sustainable Finance Disclosure Regulation (SFDR).

From our industry’s perspective, the letter clarifies that SFDR does apply to all AIFMs carrying out activities in the EU (including those gaining access through NPPRs), and clarifies the definitions of Article 8 and 9 products.

Ahead of the forthcoming AIFMD review, Invest Europe joined forces with other trade associations, such as AIMA, ACC and Inrev, to express our concerns to the European Commission on any changes policymakers are considering making to the AIFMD delegation regime. The letter explains, among others, how the EU benefits from the global nature of the fund management industry and that the EU fund management regulatory framework is robust and fit for purpose.

In this response, we comment on changes that have been introduced by the European Commission as well as present our own suggestions for Guidelines to fully play their role in allowing Member States to deliver aid to innovative and growing companies by providing targeted support to the private venture and growth funds that invest in them.

In our response, we welcome the Commission’s proposal for a CSRD and support the view that in order to achieve sustainable and inclusive growth it is key to have relevant, comparable and reliable sustainability information. That said, we ask the Commission to pay particular attention to certain aspects of the CSRD of key importance to the industry, such as the need for alignment, coherence and consistency on content and timeline with other pieces of legislation, such as the SFDR and the Taxonomy, and the importance of applying the materiality and proportionality principles when considering the extension of the scope to SMEs.