17 Jul 2025
This joint position paper by e-MFP and Cerise+SPTF contributes to the ongoing SFDR 2.0 reform process, representing social and impact finance actors investing globally in financial inclusion and sustainable development.
As networks working with hundreds of investors, asset managers, and financial institutions active in emerging and developing markets, we see SFDR 2.0 as a strategic opportunity to do more than just fine-tune technical rules. It’s a chance to reaffirm the EU’s global leadership in sustainable and impact finance, especially at a time when progress in other parts of the world is slowing due to political challenges.
But this can only happen if the revised SFDR works for all sustainable investors and investees, not just those within the EU. Today, the framework often places disproportionate burdens on those operating in emerging markets, limiting capital flows to where it’s needed most.
The e-MFP and Cerise + SPTF paper proposes 4 key areas to make SFDR truly global and fit-for-purpose:
1) Refine the definition of sustainable investment
Incorporate intentionality, “use of proceeds”, transition finance, and sustainable economic development
2) Make EU Taxonomy application more proportionate and interoperable
Recognise international standards and proxies where EU data is unavailable
3) Introduce a clear and graded product categorisation system
Avoid binary labels and create comparability across diverse strategies
4) Establish an Expert Group on Emerging Markets Investments (EGEMI)
Ensure practical guidance and inclusion of non-EU perspectives in SFDR governance
For e-MFP and Cerise+SPTF, this is not just a regulatory issue: it’s about ensuring inclusive, effective and scalable pathways for sustainable investment, especially in the geographies and communities where it is most urgently needed.
We invite all stakeholders to read our proposals and work together toward an SFDR that empowers global sustainable finance, not restricts it.