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ESG changes to MiFID II product governance regime

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28 September 2022

The European Commission has finalised its proposed ESG-related changes to MiFID II. These are intended to fit together with SFDR, and are part of a suite of ESG related changes being made via amends to AIFMD, the UCITS directive etc. However, the ESG changes to MiFID II apply more broadly than SFDR – with implications for MiFID investment firms and banks that manufacture and distribute MiFID products.

Overall, the changes are intended to put “sustainability considerations” at the heart of the EU financial system. They are also intended to “turbo charge” the European Commission’s efforts to redirect private capital into efforts to “green” the EU,  plus avoid greenwashing. One strand of the changes being made is a requirement for relevant firms to incorporate certain ESG considerations into their product governance arrangements. 

This briefing gives further detail on this new requirement and draft ESMA guidance.