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By publication of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (“Taxonomy Regulation”) in the Official Journal of the European Union of 22 June 2020, the first stage of the EU Action Plan on Sustainable Finance has been finalised. The European Union is now ready to take the next step for the achievement of its ambition to mitigate climate change by reorienting capital flows towards sustainable investments. 

After publication of the other two ESG regulations, the Disclosure Regulation (2019/2088) and the Benchmark Regulation (2019/2089), the ESG package, finally, has come full circle.


Only after the provision of clear guidance on the methodology to determine which economic activities contribute to environmental objectives and do not significantly harm other environmental objectives (Taxonomy) and by providing appropriate rules on benchmarks (Benchmarks), financial market participants (such as insurance undertakings and pension funds) and their intermediaries can communicate transparently regarding their sustainability policy or sustainable investments (Transparency). This transparency should lead to more environmentally sustainable investments, to ‘green finance’ and, finally, to a sustainable society.

The European Commission will now implement these EU Regulations via so-called ‘regulatory technical standards’, which are currently presented to stakeholders for public consultation (or will be in the near future). These regulatory technical standards will provide further practical guidance on the applicable legal requirements. 

We will keep you informed of the coming developments in this regard.

If you would like a comprehensive state of affairs with regard to ESG, including a substantive discussion, we are happy to send you our presentation (in Dutch) that we have used for our webinar of 23 June 2020 entitled “ESG – Impact on insurance and pensions”. Please send your request to