Regulation of ESG rating activities: BVI coordinates German French position 

The BVI has put together a joint paper with the German Insurance Association and the French associations for funds (AFG) and for insurances (France Assureurs). The paper outlines the following points:

• The offering of ESG raw data and ESG data products should be included in the scope of the EU Regulation.
• The exemption for financial market participants from the scope of the regulation should cover the offering of internal ratings within the group as well as in the context of mandatory publications.
• The obligations under the EU Regulation should apply to the entire group of companies of the ESG rating agency to prevent circumvention.
• ESG rating agencies should be required to publish price lists and licensing conditions.
• Market access rules for third country ESG rating agencies should be practicable in order not to reduce the ESG rating services available to financial market participants in the EU.