Consultation on the Technical Standards under the Regulation on the transparency and integrity of ESG rating activities

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Responding to this paper 

ESMA invites comments on all matters in this paper and in particular on the specific questions summarised in Annex III. Comments are most helpful if they:

  • Follow the predefined format and structure;
  • respond to the question stated;
  • indicate the specific question to which the comment relates;
  • contain a clear rationale; and
  • describe any alternatives ESMA should consider.

ESMA will consider all comments received by 20 June 2025. 

All contributions should be submitted online. Respondents are expected to use the response form in docx format.

Publication of responses

All contributions received will be published following the close of the consultation, unless you request otherwise.  Please clearly and prominently indicate in your submission any part you do not wish to be publicly disclosed. A standard confidentiality statement in an email message will not be treated as a request for non-disclosure. A confidential response may be requested from us in accordance with ESMA’s rules on access to documents. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by ESMA’s Board of Appeal and the European Ombudsman.

Data protection

Personal data contained in the file will be published as submitted. If you don't wish such personal data to be publicly available, you should not include personal data within the document you upload to a public consultation. Alternatively, you may choose the option not to have your response published on the ESMA website. For further details on data processing, please refer to the record register.

Information on data protection can be found under the heading ‘Legal Notice and Data protection’.

Who should read this paper?

All interested stakeholders are invited to respond to this Consultation Paper. In particular, ESMA encourages entities that intend to apply for registration as ESG Rating Providers, as well as financial market participants, users of ESG ratings or rated entities, to participate.

Activity Institution Download
Individuals The Credit Rating Research Initiative
  • 210746
Others Zielke Rating GmbH
  • 211112
Others Alternative Investment Management Association
  • 211114
Creative Investment Research, Inc.
  • 211136
  • 211137
Others PER CONSULTING SRL
  • 211150
Banking European Association of Public Banks
  • 211205
Others Genoa Centre for Law and Finance
  • 211206
Others Polish Association of Listed Companies
  • 211207
Issuers Deutsches Aktieninstitut e.V.
  • 211209
Others Eumedion
  • 211213
Others Cassa Depositi e Prestiti (CDP)
  • 211214
Asset Management KBC Asset Management NV
  • 211217
  • 211218
Investment Services Swedish Securities Markets Association (Svensk Värdepappersmarknad)
  • 211220
  • 211221
Others IOGP Europe
  • 211224
  • 211225
Fintech WeeFin
  • 211231
Others S&P Global Commodity Insights, a division of S&P Global Inc.
  • 211232
Regulated markets, exchanges and trading systems Samsung Electronics
  • 211676
ESG Book GmBH
  • 211246
Others Ethos Services SA
  • 211247
Others Moody's
  • 211253
Others The Future of Sustainable Data Alliance (FoSDA)
  • 211255
Others MSCI
  • 211257
Asset Management Norges Bank Investment Management
  • 211258
Asset Management European Fund and Asset Management Association (EFAMA)
  • 211259
Others European Federation for Transport and Environment (T&E)
  • 211266
Others Minerva Analytics
  • 211264
  • 211265
Asset Management Association Française de la Gestion Financière (AFG)
  • 211267
Regulated markets, exchanges and trading systems Federation of European Securities Exchanges
  • 211268
Credit Rating Agencies European Association of Credit Rating Agencies (EACRA)
  • 211270
Others EASRA (European Association of Sustainability Rating Agencies)
  • 211273
Individuals (on personal title)
  • 211274
Others RepRisk AG
  • 211276
Others Kirchhoff Consult GmbH
  • 211278
Others Clarity AI
  • 211280
Others ISS STOXX
  • 211285
Others EcoVadis
  • 211288
Legal and Accountancy Watson Farley & Williams LLP
  • 211292
Others Dun & Bradstreet
  • 211293
Individuals
  • 211295