This is Dana Perkins and you're listening to Switched on the B and EF podcast. The first quarter of twenty twenty four has seen a flurry of sustainable finance policy activity, with a wave of new mandatory reporting rules and no let up an anti ESG sentiment in the United States. It's such a rapidly changing environment, so keeping abreast of all of the global policy updates can be a tough task.
But to help, BNF recently released its inaugural Sustainable Finance Policy Quarterly Report, and this gives an overview of the most significant policy developments in Q one for twenty twenty four. This is across G twenty markets and a few other regions. And to discuss this report and its findings today, I'm joined by the author, Maya Goonomer, who is a Senior Associate for the Green and Sustainable Finance Team at BNF.
We review the climate policy environment since the beginning of the year and talk about the introduction of the Corporate Sustainability Reporting Directive in the European Union and we go through the potential impact of wider reporting standards. We then turned to the US and we review the anti ESG movement and the ramifications for green and ESG aligned investments. B and EF subscribers can find Maya's Sustainable Finance Policy quarterly at BNF dot com or at BNF go on
the Bloomberg terminal. Make sure to subscribe to switched on on Apple Podcasts, Spotify or wherever you get your podcasts, and if you give us a review on any of those, that will help share us with others. But right now, let's talk to Maya about sustainable finance policy. Maya, thank you for coming on the show again today.
Hello Dana, thank you for having me.
We're going to talk about some emerging policies that have actually well, well we've seen a wave of policies that have really come through fairly recently, and we're going to get into this policy discussion as well as a new tracker that we've made at BNF which is a US anti ESG tracker. But before we get to the ANTIESG parright,
let's talk about these policies. What would you say have been some of the developments or you know, really when you're speaking to people who are looking closely at ESG, what are some of the frameworks and potentially conflicting parts of frameworks that people are discussing at the moment.
I think we're reaching that point where we have so many of them. So what's keeping sustainability professionals up at night is trying to basically reconcile everything that they are seeing. Most companies and firms are global firms. So one of the key developments we've seen in the past quarter is the USSEC, the Security and Exchange Commission passing finally its
climate role or reporting for companies. But that has been passed, and then straightaway has been posed because of so many legal issues and potential lawsuits to prevent it to see the light. And then in the EU there were again more policy development targeting companies around disclosure, around integration of sustainable matters. They are conflicting reporting standards that are basically
popping up around the world. The International Sustainability Standards Board built a framework called the IFRSs one and S two. I'm so sorry, but these are the names. Actually there is not a longer name than that, and it's basically a sustainability reporting standard that is looking at sustainability risk and climate risk. That is a key standard where the same way we build the IFRS, accounting we're building that new, big global standard, so that after countries are implementing.
It, but everyone is implementing it a tiny bit that like differently than the other, you know, and you add all these layers of complexity, and you're like, when I took to sustainability professionals, whether they are in a bank or they're in a company, they just are.
Like, where should I start from? Like which one should I report against the first? Which one is the most important, which one is the most complicated? And I think the key ones are, Yeah, these ISSB developments, the us SEC, everyone had all their eyes on it. And in the you there were two key policies, the Corporate Sustainability Reporting Directives CSRD and the CS three D, the Corporate Sustainability Due Diligence Directive, which this one is about sustainability, integration
and really actionable stuff. But then people are basically asking us what's the most important and how do they interact with one another?
So for we're thinking about the fact that these are mandatory that are coming through more often that is essentially calling people's hand when they're thinking, well what do I start with? It's the governments are defining what is the imperative most immediately. But why do you think that is.
Is it showing a sign of sophistication within this market or is it showing more a sign of what you were just actually talking about, which was that there is so many different frameworks that someone has to essentially say this is what matters and this is what's optional.
There is sophistication arriving in this market. There is a need for standardization. We've talked about it so much, but up until now it was like, oh, we're going to create a standard and then people can abide with it or not, but you need to impose it effectively. We used to have so many different for instance, on the corporate level, so many different reporting standard I'm going to name abbreviation, but it's just to give an idea to people.
It's like you had the TCFD task for some client related financial disclosure, you had CDP, you had gr I, you had says by like, so many to choose from, and effectively, if no one says okay, that's the one, everyone is going to follow, well you just get a range of reporting that are all different from one another.
And then if I'm an investor or a bank and I want to make action on the back of this, then you need to spend an extra amount of time to standardize all these data and compare it to one another. And then because at the end of the day, you just want to compare one company to another on the back of their environmental, social and governance factors and performance.
But presumably wouldn't these different reporting frameworks being speaking to from the company standpoint to different parts of the financial services community and designing that reporting in a way that is most digestible to different and financial end players which do have different strategies and are looking at things differently. So what equities are going to need to be able to ascertain, you know, what, compare one company to another.
It's going to be different than what the credit market actually needs in order to be able to make those comparisons.
It could be it could be something like that. I think it was more like appealing to different companies depending on their type of service or the thing they wanted.
To report on.
They would choose TCFD, if they wanted to report on their exposure to climate risk, they would choose SISB, or to report on their overall sustainability performance, or they would use CDP to report on their climate performance. Now what's happening, and in particular in you with the Corporate Sustainability Reporting Directives ESORD, so they're like, you need to report on everything. You need to report on social you need to report on governmance, you need to report on the environmental side.
It's a double materiality framework there there it is the big word have been said, which is like looking at both how much climate how much social factors are affecting the profitability of a company, the profitability in good or bad. So that's the financial materiality, but it's also looking at how much the company's operation are affecting the environment or effecting society. So that's CSRD, but that means more than
one thousand and two hundred data points. On the other side, you have ISSB, which also tried to encompasses all these like metrics. So the ISSB framework is looking at both sustainability risk. So that's the IRSs one and the IRSs two looks at climate risk disclosure and the IRSs two. I keep on saying this to client and makes them laugh.
When I saw it, I thought it was TCFD, Like I was just like, can't be that everyone is talking about this thing, and I just don't understand, like it seems like it's like, you know, like when you feel like a groundhout day, Like you know, it's like I've seen this before and it's effectively TCFD, But then looking at climate and looking at sustainability matters.
It was an evolution of it.
It's an evolution of it. It's building on this framework that has been like widely use. A lot of work has been done by the TCFD team to promote the use of that framework across the globe. And actually TCFD retired because it's incorporated in ISSB now, so it doesn't exist anymore. But the only difference is that, however, ISSB is like free form. It's not structured, it doesn't have key metrics you need to report on.
So in many respects, the voluntary frameworks existed as a form of carrot. You got to pick the one that was best for you, and it was a really more positive way of going about the reporting. And that now these mandatory frameworks are a little bit more of a stick, so you're going to have to comply. And what you're pointing out is that in some cases they're actually an evolution. They built on these voluntary frameworks to then create these
mandatory frameworks. But we haven't necessarily retired all of the voluntary frameworks in order to create space for the mandatory ones. And that may be something that we do end up seeing over time. The future will let us know whether or not that ends up being the case. But let's go back to this conversation around the CSRD and the ISSB, one being mandatory and one being voluntary. Yeah, where is the friction between the two and why is their friction?
Why would you choose one over the other. Well, I guess you're not choosing the CSRD. The CSRD is an imperative in certain parts of the world.
Yeah, So, I think one thing that is really important to understand between at this shift between voluntary and mandatory is also the state of the market. The more advanced to get into that sustainable finance market, the more you want to force your banks, your investors, your insurance to take into account sustainability risk and climate risk in the investment processes and the decision making processes, the more you'll have to make it mondatory because they'll need the data
to do this. You can force a climate risk stress test onto a bank and say, you know what, you figure out with the data you've got, we're not going to mandate reporting from companies, So that that's the ground. And then for ISSB versus CSRD. So ISSB is a voluntary framework, just because the IFRS foundation the same way for those of you who have studied a accounting just like me, as just an accounting standard, and then countries
can choose to opt on it or not. So DA first was like, okay, we're going to build that standard, and then after every single jurisdiction will adopt it or not. So certain jurisdiction are making iss be a reporting mondatory. So that's the case of Turkey, that's the case of BRAZILA is thinking about it, that's the case of the UK. Like there are tons of jurisdiction across the globe that
are making it mandatory. Progressively, some of them are starting and being like okay, to start with, we're going to make it voluntary, and then it's going to become mandatory eventually. The friction comes from the fact that okay, we have all these different jurisdiction adopting it, tweaking it a tiny
bit so that it meets their local requirement. And then you have this mammoth of CSRD, which is an EU legislation that is affecting fifty thousand companies globally EU and non EU company public and private company SMEs because the EU has said, okay, we're going to build this new reporting standard, and basically any company that is domiciled in the EU but also trades in the EU, that has a certain amount of revenue in the EU, that is listed in the U, all these companies are falling in
scope first years or if you're doing business in the EU, you're most likely going to be in Yeah, exactly. So it's phased in the implementation from now like the first reporting or starting next year publication of reporting, but it's starting this year, but publication next year up until twenty
twenty nine. There's going to be time. There are these like that thousand of metrics, but for each metric you have the right to say, actually that metric is not material to my business, I'm not going to report on it. So there is that flexibility around that. But it's still a bloody mammoth, like it's massive. Some companies I'm talking to their like we have to capture data we've never captured before.
I mean, how many people have they had to put on to these projects that they had to add We're taking double digit people to actually work on this reporting or is it single digits?
It really depends on companies, but I think, yeah, I think there are all building teams to do that. And when I took to companies, some of them are like, you know what, I fall in scope for iss B reporting n CSRD. CSRD is so stringent that I'm just going to do CSRD and then de facto I'm going to do my iss BE reporting.
Do you lose anything by just doing CSRD.
I don't think so. It's so complicated and thorough that you don't. And actually, last week the two authors of CSRD and ISSB and I'm not going to go into the abbreviation again, but there are two author groups, some
that built CSRD and some that build ISSB. I've published what we call an interoperability guidance, which basically allows company to efficiently do the two at the same time and be like, these are all the areas where the two frameworks collide and where you can gain some time by doing one and the other at the same time.
One of the things that's really interesting about the is this is it is truly global. It is not just European or just North American. You're finding it in Brazil, Costa Rica, Singapore, Turkey, and then recent markets that have announced that they will be reporting you in using the ISSB framework Pakistan, Kenya. I mean, this is a truly
diverse set of countries representing different continents. Do you think that those outside of Europe will continue to say, well, not all of the business of all of the companies that we are actually working with need to embrace the CSRD because that's not necessarily where their business is. And the ISSB will continue to remain dominant in other parts of the world.
For many reasons. ISSB is an easylyft. It's much easier when like from a diplomatic standpoint and a political standpoint, when you're like a government leader to impose ISSB than to impose something like CSRD. CSRD has been in the work for a very long time, but ISSB is like you know, free for much more qualitative. It leaves much more or room for interpretation. You don't have like exact
metric you need to report on it. It's not like, oh, you're a cement manufacturer, you need to report the amount of Scope one, two and three emissions that you emit, while CSADY has CO three emission. And so depending on which stage you are at the development of the sustainable findance market, how much the rest of the institutions within the country want to integrate sustainability within their own requirements, you know, like the financial regulators and whatnot, then they
probably will be more inclined to mandate ISSB reporting. Also, if they have never mandated anything before, they are very likely to be undating ISSB. Also, as I said, ISSB draws a lot of inspiration from TCFD, and TCFD has been very popular, so it's easy to say, you know what, you've been doing TCFD for such a long time, move on to ISSB. There are some tweaks here and there. They are a bit different. You need to first do climate risk reporting and then you need to do that
sustainability reporting. So just expand to other areas. I think that's what we're going to see. But what we might see is companies themselves saying I'm going to report voluntarily against CSRD. So there was like a survey published last week on Bloomberg that says seventy percent of the companies that we're not in school for CSRD, but answered that survey we're planning to at least partially report against CSRD. Seventy percent. That's massive, and that's across the globe.
So I may have oversimplified the ISSB is voluntary versus the CSRD is mandatory, because we know the CSRD is being implemented in the U and pretty much any company that's touching the EUS The way we're framing it with ISSB as it being voluntary in theory when countries adopt it and say that they're going to phase it in, and there actually have been a number of countries that have actually announced it that they will be implementing it
in the future. I think across thirteen markets that are in the process of implementing this, it's no longer voluntary in those specific countries. So can you kind of clarify what voluntary even really means if ultimately the destiny for some of these reporting frameworks like the ISSB is getting adopted and becoming mandatory in certain jurisdictions.
Yeah, CSRD has been built straight away to be a mandatory framework and being implemented is been built, so there is a standard behind it that's been built to be the reporting framework that is mundated by the EU ISSB. At the beginning, it's a bit like how TCFD worked back in the day, Like it's that framework that has been built by a third party association, the IFRS foundation. That was like, we're building the standard. Whoever wants to
use it uses it. And when I say whoever, countries who wants to.
Use it, say, we've done the work for you.
We've done the work for you. The standard has been built. Instead of all of you creating your own standard because we know you're going to be willing to mundate sustainability reporting, instead of choosing a different standard to mum d that reporting, we're going to build one standard and then after you're going to build laws in your own jurisdiction that moundate reporting against the same standard, which is ISSB. So the same way back in the day, we had countries saying
TCFD exists, we ask you to report against TCFD. That's the law. The law is to say you need to report, and the standard you need to choose to report is TCFD. This is what is happening right now.
So it just has to do with the organization that created it, having a lack of authority over countries, but ultimately wanting it to become exactory in a number of ocations.
And then that foundation that was built to develop the ISSB was endorsed by many different countries, including the EU, saying okay, we need a global standard so that instead of going all in our little corner and asking companies to do a reporting that is a tiny bit different from one another or completely different, then we're going to have a standard we can all abide with. On the other side, the CSRD relies on its own standard that has been built by the EU themselves. It's called the
European Sustainability Reporting Standard. So effectively, when I took about CSRDVERSSSB, it's effectively the European Sustainability Reporting Standard ESRs against ISSB. These are the two different reporting standard. One is going to tell you need to build that table. The other one will tell you you need to be that other table.
That's what is different. So then in itself ISSB does not mandate anything to anyone, but then it's being endorsed by government and put into law in different jurisdictions.
Well, and among this list of governments that have adopted this, there seem to be a number of emerging markets who have actually signed up for it. And do you think there's any particular reason that it has been popular in emerging markets.
I think it's because the ISSB standard is an easy lift when you're at the beginning, in the early stage of developing a sustainable finance market. It means that if you want companies to start assessing their exposure to sustainability and climate risk, the ISSB is not that difficult to get a political approval on because it's just single materiality, so it's just looking at the financial impact of sustainability matters compared to the CSRD that I explained earlier, So
that makes it easier. And it's also an easy lift because it's very much like as I said, it's super similar to TCFD, so you had already a lot of companies that had endorsed that framework, and it's just like expending a tiny bit the perimeter of TCFD. So that might be the reason why. The main thing we might see, however, is that with CSRD ISSB, all these different like reporting framework popping up is that what I hear from companies is companies are saying, we're happy to do all these exercise.
We know we have to report on new stuff, on new factors. We're happy to devote the teams to do that, to put the means towards building this. We think it's actually representing our business a bit better. However, if investors that have like a good sustainability performance, I'm talking on the companies that are training, like, look, we're actually making
an effort. What they're telling us is that if this doesn't lead in investors to invest more in us to decrease our cost eff equity, to decrease our cost of debt, Basically, that like not reward us on the back of the all these efforts that we do just going to end up doing it as a compliance stickboxing exercise.
And it's not going to drive the same level of change that it potentially exactly, which then leads us. So I want to make sure that we have enough time to talk about this new tracker that we've made focused on anti ESG legislation, specifically in the US, which is the other side of it. So as we end up seeing more legislation mandating reporting and trying to you know, really rally people around, coming up with a common set of metrics and the ability to make decisions based on
better quality data. When it comes to sustainability, there's been this movement, if you will, across a number of US states that have essentially said that, well, maybe that reward in terms of performance doesn't necessarily exist and it could be at conflict with fudiciary duty. Therefore ESG is not allowed in our state. And even if you're not on Walls Street in New York and the amount of money moving there, pension funds are a big deal and states
control a lot of pension money. So can you talk a little bit about, well, first of all, how many of these anti ESG bills have passed? Where they are you know, really what's happening in the US with that.
We've seen more than fifteen ANTIESG policy being passed in the US. And when I say ANTIESG policy, there are two kinds. Anti ESG is like the main title, but there is one that is truly anti ISGU, which is, as you said, it's been questioned whether undamental social and governance factor are actually financially material.
And there is data suggesting one or the other. So it depends on I mean, it's almost a philosophical view, depending upon what data you're going to adopt and what studies you actually want to evaluate. Because certainly on the other side, there are plenty of studies that do say that it improves financial performance, especially over the longer term.
Exactly on the medium to long term. And so a certain state have said, you're breaching your fuduciary duty, which to explain to our od and so if you're like not from financial markets the future duties to duty an investor has towards its clients, which is to make the most profitable financial decision for them, taking into account their preferences in terms of risk and return. And so they say, okay, we don't want any state pension to take into account onunrontal,
social or governance factors. So that's an entire year, is you know. The other type of flow is like much more straightforward, which is like it's called the boycott law, So it's basically boycotting any financial institution and sometimes even companies that take into account sustainability and that the state
deems to support. Sustainability matters. So certain state have completely banned numerous financial institutions in the likes of black Rock, BNP, PARBA, a lot of European financial institutions as well, because they deem them to be pushing a sustainability agenda. We're talking about more than fifteen states, and.
They're boycotting the entire organization or just the funds that actually use the SG criteria because these different desks do operate separately from each other and have different standards that they hold themselves to.
No the entire financial institutions, which leads them in certain cases. There was one of the state that it led them to basically not being able to raise their state level debt. For financial institutions, it's actually it's beyond investors. It's like you have a smaller list of banks that will be able to underwrite your debt and get you the best
deal for your debt. So you end up having to raise your debt through an auction process, which is much less financially interesting and paying higher interest rate because you don't have the same ability to go through an underwriter aka a bank. Because you've banned bnppre Aby, you've banned HSBC, you've banned Barclays and Therefore you reach a lower investor pool, and you have less people to sell your bones to, and you pay a higher interest because there is less a bidding wharf for your debt.
So there are negative, arguably unintended consequences of this legislation for the states that have passed it. But how about on the other side, So the companies that actually want to attract this pension fund money, are they changing and are they essentially abandoning their ESG rules in order to attract it.
So what we found very interestingly, and some of you who are familiar with the market have seen this as well, is that companies, investors' state level institutions as well sometimes continue with these strategies. They continue to integrate environmental, social, and governance matters, They continue to have a sustainability strategy, they just don't talk about it or like they switch
on and off who they talk about it too. The companies of these states, they'll still have to attract international investors, and for that they can't negate the need to have, like, for instance, a sustainability strategy. It's just that they might not like present it to everyone. A key example, like from a data perspective, we have like a concrete example.
For instance, in the state of Florida, there was a law being passed where Florida Institution could not raise any sustainable bond, so they were not allowed to raise a green, social or sustainability bond whatsoever. And what we've seen is that there is a county within the state of Florida that issue the bond after this law was passed, and it's technically a green bond because it was done for
biodiversity protection and land protection purposes. But the county, which is Hillsboro County, has decided to not label that bond, which was twenty seven tranches, as green, so it shows that it's being done. The money is raised for green purposes because this is going for land and biodiversity protection, but it's just not being labeled as green anymore.
Well, because presumably it's a good investment and they're focusing on it anyway. And maybe that's the argument, is that the investments will still happen, yes, if they are good investments, but they won't be under the guise of ESG. It'll just be an investment like any other.
Yeah, exactly. So we're going like ten years back.
So how about the states that have a commitment to ESG frameworks and making sure that sustainability is taken into consideration for their pension funds, because all of these financial institutions want to attract that money as well, so they're kind of caught between the two. Are there the same number more less of the pro ESG side of things, So there are.
Less pro ESG laws being passed in the US, but there are still a substantial amount. So what we call a pro ESG look can be either a disclosure lad that we've seen in California or a divestment law basically asking pension funds in the state to divest from certain sectors. And these are being passed in state, and there are more in the pipeline, and maybe the presidential election is
also going to have an impact on that. So these are being passed and effectively there's still like an unstoppable trend that will continue.
So do you think we've seen an end of these laws, whether pro or anti in the US? Specifically those states that are kind of straddling the middle of the line and not taking a stance, do you expect more of them to essentially make a decision as to what side of this they fall on.
No, we are seeing more in the pipeline. We're seeing the state that have already passed pro and anti ESG LO continue to push more lows, and we're seeing new states having lows in the pipeline as well.
So we're seeing some of the pro ESG states being Massachusetts, Washington, and some of the anti states being like Florida Texas. Are they following the typical voting red and blue state lines so largely.
Yes, with some exceptions to it, but important like red state have passed these kind of floats such as Florida, Texas, Alabama, which we're not surprising, and California has passed one of the first pro ESG LOO. Indeed, there is a correlation there.
The reason why there is this trend of pro versus anti ESG lows in the US at the state level is that, compared to other parts of the world, in the US, promoting sustainable finance and promoting ESG investment is seen as a politic agenda, and that's very, very very important. It's a big distinction compared to other parts of the world where we're seen in the EU and in the UK for instance, or even in Singapore and Hong Kong.
It's been seen from a prudential regulation vision first, as in the goal and it was the work of the Carnes, it was the work of the Christiane la Guard back in the day to say sustainability risk and climate risk or real risk, they pose risk to financial stability. The financial regulators are really pushing towards like trying to prove
this out. And the way to prove this out is seeing central banks publishing reports to say, hey, we've assessed the reliance of our economy onto climate and how much climate change is going to impact the profitability of companies
and stuff like that. Last week in the UK there is the Green Fightens Institute that's just published a report to show, oh, there is big reliance of our corporations on ecosystem services on nature and therefore if we don't force financial institutions to take into account nature risk, then is going to cause like a big financial stability problem. Same in the you. So the first stage is always that research stage to prove that it's not a political agenda.
And in the US I think that we're still struggling with that. And therefore if you promote ESG, you're promoting a political agenda, so.
It really transcends policy. And the fact that I even asked that question despite living in the UK for eighteen years shows just how American I am.
Yeah, but I think that's what is really really interesting about this situation.
Are we seeing anti ESG legislation outside of the US.
No, absolutely nowhere, So.
Everywhere else it's either your adopting a policy or actually just getting on with regular business and not really thinking about it exactly.
That it's really an outlier. And actually, when we published a report, there was this chart that I was hesitating into including because it shows the US as the largest number of sustainable finance policy in the world. But that's only because they have all these anti ESG barriers and they account for more than half of the sustainable finance policy in the US. But it's also because of them.
We need to bear in mind that certain countries have expanded the bund dates of financial regulators, so for instance, in the EU, it's much easier for certain regulators to pass policies to promote sustainable finance, while in the US it's much more complicated.
So my last question is just really who do policies And we're going to talk about them globally in this context, who do they impact most? Are they targeted towards the investors? The corporations credit agencies I know also have some policies focused on them. What is the breakdown of who needs to care the most about this?
I'd say up until now it was mostly corporations, And I usually take this example for me. Sustainability data from corporation is basically the main commodity for a healthy sustainable finance market, the same way that we need data for a healthy financial market. You know, corporations where the largest impacted target group, but that's shifting away to really target
investors and banks. Now investors are the most targeted group as of like this this quatter, but that's also because they are not being asked just to report on ESG reporting, you know, like to do ESG disclosure. They are asked to then integrate ESG into their investment processes. They are asked to do climate risk management, they are asked to do reporting, They are asked to take into account new sustainability preferences from their clients. Like there is a wide
range of the men that are done for them. And then banks are also being targeted a lot banks are very targeted on the risk side, like climate risk stress testing, climate risk management, climate risk disclosure, which is necessity to prevent that economic meltdown if they don't take into account these risks. But it can also have a great impact on the energy transition, and that's like one of the
goal at BNF. The way we see that research is how are all these policies eventually supporting the energy transition, how are they driving new investment and effectively asking to take into account climate risk and sustainability to risk in our view is to say, okay, then there's probably going to be a shift in investment. If you start taking into account climate risk, then you will probably shift your portfolio towards more climate resilience, energy solutions, and solutions for
the future. So to answer your question, corporations, investors and banks with now a few posts looking at credit rating agencies, exchanges, data providers, all these kind of intermediaries that make a healthy financial market.
But that's a much smaller so much more diction. Indeed, Well, maya thank you for clearing things up for me on this recent wave of policy that has come through and kind of some of the things that we need to know we didn't even get into the taxonomy changes that have gone through, so there's always a need to have you back to clear things up for us. And thank you for joining today to talk us through.
Thank you so much.
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