FinDatEx

Today, FinDatEx launches a public consultation on a new European ESG Template (EET) and an update of the European MiFID Template (EMT). The consultation is open for feedback until 25 February 2022. The templates can be found under “work in progress templates”.

European ESG Template (EET) v1.0

In view of the extensive current and upcoming regulation on EU level requiring the exchange of ESG-related data between the manufacturer and distributor of financial products, in April 2021 FinDatEx decided to create a dedicated working group and introduce a stand-alone data exchange template. After intensive work, the group is now proposing the EET v1.0 and offers market participants the possibility to comment on the near-final draft before adoption.

The EET is a cross-sectoral template comprising the views of the banking, asset management, structured product, insurance and pensions industries. The EET v1.0 contains a high number of data fields focusing on the implementation of the SFDR level 1 and RTS, as well as the delegated acts complementing MiFID II and IDD with regard to the introduction of the concept of clients’ sustainability preferences. Content and structure of the template have been intensively discussed and were subject to numerous feedback rounds. They reflect the current regulatory situation and market needs. FinDatEx is thus now seeking further feedback on the content of the data fields while the overall structure will remain as it is.

The template has been drafted in the same style as other FinDatEx templates, using the Excel format and applying the same naming convention, abbreviations and separators.

The template is structured in the following main parts:

-       Disclaimer

-       EET Data Set Information

-       Manufacturer Information

-       Product or Financial Instrument Data

-       Principle Adverse Indicators

-       Screening Criteria

-       Country Specific Information (Mandatory in the country of distribution)

Columns A to E explain the content of the data fields by providing the data name, definition, codification and comments. Columns F to Q determine whether a data field has to be filled out on a mandatory (M), conditional (C) or optional (O) basis, and differentiate between the different regulations and product or entity aspects.

Furthermore, separate tabs provide information on stewardship codes, an ESG-labels standard list, commitments, the regulatory schedule and country specific information.

European MiFID Template (EMT) v4.0

The introduction of the EET requires an update of the EMT. The EMT v4.0 will replace the currently co-existing v3.0 and v3.1 and will then be the only version of the EMT for use.

In comparison to v3.0 and v3.1, the following changes have been made:

-       The disclaimer explains the rationale for the update and the interplay with the EET.

-       The wording of data field 05105 has been updated.

-       The country specific ESG-related data fields of v3.1 have been deleted.

Next steps

After taking into consideration the feedback received by stakeholders, FinDatEx intends to make the EET v1.0 and the EMT v4.0 available to the public by mid-March to allow for technical implementation and coding. Delivery of the EET by product manufacturers should begin on 1 June 2022, and the EMT v4.0 should be used as of 1 August 2022. In line with the usual FinDatEx policy, both templates will be free-of-charge and intellectual property rights, and its use will be voluntary.