FinDatEx

FinDatEx publishes the first version of the European ESG Template (EET V1) and a corresponding update to the European MiFID Template (EMT V4). Both can be found on the FinDatEx website under "Current templates".

European ESG Template (EET) V1

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 has now published the EET V1.

The EET is a cross-sectoral template comprising the views of the banking, asset management, structured product, insurance and pensions industries. The EET V1 contains a high number of data fields focusing on the implementation of the SFDR Level 1 and current draft RTS, as well as the delegated acts complementing MiFID II and IDD with regard to the introduction of the concept of clients’ sustainability preferences.

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

The introduction of the EET requires an update of the EMT. The EMT V4 will replace the currently co-existing V3 and V3.1 and will then be the only version of the EMT going forward.

In comparison to V3 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.

FinDatEx recommends the EET V1 delivery by product manufacturers from 1 June 2022 and the use of the EMT V4 from 1 August 2022 in light of the revised MiFID II and IDD delegated acts applying from 2 August 2022.

The FinDatEx templates are free-of-charge and intellectual property rights and their use is completely voluntary.

The work on ESG-related data fields started in July 2020 and on a separate ESG-Template in April 2021. It required more than 30 full working group meetings, each 4 hours long, numerous subgroup meetings and several info sessions were offered. FinDatEx would like to thank all active group members for their valuable contributions and most of all the coordinators of the ESG working group – Joakim Alpius, Nathalie Dogniez, Ghislain Périssé and Michael Pilous – for their dedicated and relentless work to have made this new template possible.

Since the regulatory ESG landscape is constantly evolving, the group work will continue on a permanent basis. The EET will be reviewed regularly, and confirmed at least on an annual basis.