Consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD

Consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD

from 19 December 2018 to 19 February 2019


Responding to this paper  

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

1. respond to the question stated; 
2. indicate the specific question to which the comment relates; 
3. contain a clear rationale; and 
4. describe any alternatives ESMA should consider. 

ESMA will consider all comments received by 19 February 2019.  

All contributions should be submitted online at  under the heading ‘Your input - Consultations’.  

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 

Information on data protection can be found at under the heading Legal Notice

Who should read this paper 

This document will be of interest to UCITS management companies, self-managed UCITS investment companies, AIFMs and their trade associations, as well as institutional and retail investors investing in UCITS.

A video recording of ESMA’s hearing on ‘Measures to promote sustainability in EU capital markets’ is available on ESMA’s YouTube account


Document available for this Consultation
19/12/2018ESMA34-45-569 Consultation paper on integrating sustainability risks and factors in the UCITS Directive and AIFMD


Activity Institution Download
Iñaki Viggers
ZIA Zentraler Immobilien Ausschuss e.V.
Managed Funds Association
BIPAR (European Federation of Insurance Intermediaries)
Asset Management BNP Paribas Asset Management
Asset Management Mirova
Asset Management BlackRock
Asset Management INVERCO
Asset Management Slovak Association of Fund Management Companies
sass_response.pdf (172.92 KB)
Asset Management Amundi
Asset Management ALFI (Association of the Luxembourg Fund Industry)
Asset Management Invesco
Asset Management European Fund and Asset Management Association
Asset Management DUFAS (Dutch Fund and Asset Management Association)
Asset Management State Street Global Advisors
Asset Management Amundi
Asset Management Robeco
Asset Management Invest Europe
Asset Management ICMA
Asset Management Hermes Investment Management
Asset Management BEAMA (Belgian Asset Managers Association)
Asset Management Ruffer LLP
Asset Management Schroders plc
Asset Management Sustainable.AM
Asset Management BVI
Asset Management Austrian Association of Investment Fund Management Companies
Asset Management The Investment Association
Asset Management Bundesverband Alternative Investments e.V. (BAI)
Asset Management ICI Global
Insurance and Pension CCOO FP
190215_esma_5.docx (14.04 KB)
Insurance and Pension Corporate pension fund
190218_esma_0.docx (14.04 KB)
Insurance and Pension Aviva Plc
Insurance and Pension German Insurance Association (GDV)
Insurance and Pension CCOO FP
190215_esma.docx (13.97 KB)
Insurance and Pension CPPS
190215_esma_0.docx (13.97 KB)
Insurance and Pension Repsol
190215_esma_4.docx (13.97 KB)
Investment Services ANASF - Associazione nazionale consulenti finanziari
Investment Services European Federation of Financial Advisers and Financial Intermediaries (FECIF)
Invididuals BETTER FINANCE - The European Federation of Investors and Financial Services Users
190215_esma_1.docx (13.97 KB)
Others FNV Gobal Union
Others Af2i Association francaise des investisseurs institutionnels
Others 2° Investing Initiative
Others INREV - European Association for Investors in Non-Listed Real Estate Vehicles
Others Confederación Sindical de Comisiones Obreras (CS CCOO)
190218_esma_2.docx (14.04 KB)
Others European Financial Congress
Others PRI Association
Others Finance Watch
Others CCOO Servicios
190215_esma_2.docx (13.97 KB)
Others Association Française de la Gestion financière
Others Social Impact Investing Implementation Taskforce
Others AIMA
Fintech SD-M GmbH