Erhvervsudvalget 2019-20
ERU Alm.del Bilag 347
Offentligt
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Valdis Dombrovskis
Executive Vice-President for An Economy that Works for People and Com-
missioner for Financial Services, Financial Stability and Capital Markets
Union
European Commission
MINISTER FOR INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
Dear Executive Vice-President Valdis Dombrovskis
Thank you for the opportunity to respond to the European Commission’s
public consultation on a Renewed Sustainable Finance Strategy. It is a key
priority for the Danish government to enable a transition to a green and
sustainable economy, and we therefore welcome this consultation.
The EU has so far lead the path towards sustainability and this role should
continue in the future, as EU can be a world leader and push development
on both on the national, EU and global level.
The financial sector has a key role to play in the transition by enabling other
sectors to transform. Denmark is therefore dedicated to supporting ambi-
tious efforts to further develop the area of sustainable finance, which con-
tinues to be growing. In our view, the growth of sustainable finance will be
pivotal in fulfilling our commitments under the Paris agreement.
Generally, it is of key importance to find a balanced approach to sustainable
finance, developing markets while ensuring financial stability. This is the
case as we see financial stability as a prerequisite and a foundation for sus-
tainable finance, as stable financial markets and predictability is needed
before investors turn into areas with some uncertainties, such as sustainable
finance.
Nationally,
we should scale up well functioning and innovative initiatives,
and learn from best practices from other Member States. We generally see
a big potential for the EU to be a platform for Member States to exchange
ideas, experiences and successes. We should also continue to ensure guid-
ance to stakeholders to help them understand how the rules would apply to
new solutions and technologies.
On the EU level,
we support both legislative and non-legislative initiatives.
These initiatives should be in line with climate targets and focus on areas,
which hold considerable potential or pose as barriers to the sustainable tran-
sition. Initiatives should raise awareness of green investments as well as
ensuring access to adequate and easily understandable information in order
for investors and clients to make informed choices and assess risks, includ-
ing those posed by climate change. In this context, communication should
be reliable, transparent and unambiguous. This will include further work to
ensure correct measuring of the degree of sustainability in portfolios and
MINISTRY OF INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
Slotsholmsgade 10-12
1216 Copenhagen K
Denmark
Tlf.
+45 33 92 33 50
Fax.
+45 33 12 37 78
CVR-nr. 10092485
EAN nr. 5798000026001
[email protected]
www.em.dk
ERU, Alm.del - 2019-20 - Bilag 347: EMs notat vedr. høringssvar om en fornyet strategi for bæredygtig finansiering, fra erhvervsministeren
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investments, how transition activities can be addressed as well as secure
standardised, high quality data.
Among possible suggestions for concrete proposals, we are very supportive
of introducing Eco-labels for products targeted retail investors and clients
as this addresses the heart of the challenge of easy access to information
for this target group.
We also support a legally binding framework for the EU Green Bond
Standard as long as such a standard would also cater to the needs of Mem-
ber States with low sovereign debt. Therefore, it is important that a future
EU Green Bond Standard is constructed so that it embraces more than just
conventional green bonds.
Denmark finds verification and supervisory processes very important for a
standard to be successful, keeping in mind that such requirements must not
stand in the way for well functioning or new innovative solutions.
Successful and wide uptake by as many stakeholders as possible of current
and coming initiatives is dependent on legal certainty for all actors. Thus,
we should fully take into account the most recently agreed legislation and
leave adequate time for it to take effect and be applied before introducing
possible changes.
On a global scale,
considering the global nature of the challenges ahead,
we believe it is important that the EU continues to act on the global level.
In this way, the EU should promote the valuable initiatives in the space of
sustainable finance globally, including but not limited to, the uptake of the
taxonomy for sustainable investments. We believe the International Plat-
form for Sustainable Finance is a good forum to achieve that goal.
In conclusion, we very much welcome the work towards a renewed strategy
for sustainable finance and we look forward to contributing actively to the
process.
Attached please find our specific replies to the consultation document. As
always, I am at your disposal should you have any questions or comments.
Yours sincerely,
Simon Kollerup