FNG-Short Report on the Occasion of the Eurosif Market Report 2018 // 27.11.2018
For the first time the FNG – Forum Nachhaltige Geldanlagen: the Sustainable Investment Forum of Germany, Austria and Switzerland is publishing a short report on its own market data for Germany, Austria and Switzerland (DACH region) in comparison to developments in the European market as a supplement to the FNG Market Report 2018.
The FNG short report will be released at the same time as the Eurosif market report. It became necessary as the emerging market dynamics for responsible and sustainable investment in the past two years as well as the EU Action Plan on "Financing Sustainable Growth" (EU Action Plan) led to different terminologies in the EU countries in the interim period. One of the main objectives of the EU Action Plan is to achieve a common understanding of the potential of sustainable and responsible investment. Unfortunately, this could not be implemented simultaneously in all countries for the collection of market data for the 2018 Eurosif market report. As a result, different survey methodologies were used for the country reports in 2018.
From FNG’s point of view, the current Eurosif market report therefore does not correctly reflect the differentiation of the DACH market in accordance with the definition recently introduced by the EU Commission. In our opinion, the Eurosif data leads to a clear misinterpretation of the dynamic market development in the DACH region, as it does not take into account the current debate on sustainable finance. Therefore, we have supplemented the pan-European overview pages of the current Eurosif report with the from our point of view correct and complete statistics from the FNG Market Report 2018 and the corresponding country chapters in the Eurosif logic, as shown below.
What is behind the divergent data between Eurosif and FNG:
- As a result of the Sustainable Finance debate, since several years a clear distinction between fiduciary (responsible) investment (RI) and sustainable and responsible investment (SRI) has been made in Europe.
- In the EU Action Plan the two categories are also clearly distinguished and different measures are derived from both.
- In view of the foreseeable discussion in 2019 on a qualitative assessment of sustainability aspects as part of the fiduciary duties for investment and its verifiability by the supervisory authorities it is necessary that this RI is also recorded correctly - separate from the SRI data.
- For that reason, FNG conducted a separate query on fiduciary duties with regard to sustainability and explicitly sustainable financial products in the current, but also previous FNG market report. You can find these definitions and explanations in the FNG market reports as well as in this short report.
- As previously described, the methodology based on this distinction has not been adopted by all other countries yet, resulting in different survey contents and results that are not easily comparable.
- This leads to an under-representation of the data of Germany, Austria and Switzerland in comparison to the other countries and to the fact that the country data in the Eurosif market report is not comparable. Roughly speaking, the data assessed by FNG for both RI and SRI corresponds to the gross values of the other countries included in the Eurosif market report.
Unfortunately in 2018 we were not able to find a representation of the data that satisfied all persons responsible for the Eurosif report.
As FNG, we are convinced that, as an industry association, we are responsible for a timely representation of the markets. We should therefore not only present the data based on the current legislative framework, but already take into account political and market developments on which we are also taking a position in the public debate with our numerous stakeholders.
We hope that in future discussions within Eurosif, we will be able to agree in a timely manner on a common survey methodology that will ensure comparability between the country markets again.
Until then, we kindly ask you to only use the numbers and overviews listed below for the German-speaking markets. This serves the purpose of a realistic, more differentiated and constructive debate on the further development of responsible and sustainable investment.