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EU’s Regulatory Framework for ESG Rating Agencies: Promoting Transparency and Reliability in Sustainable Finance

The European Commission (EC) has recently released a sustainable finance package that includes a regulatory framework for Environmental, Social and Governance (ESG) rating agencies. The proposal aims to facilitate the flow of capital required to finance the EU’s sustainability goals, including reducing greenhouse gas emissions by 55% by 2030 and achieving climate neutrality by 2050.

ESG ratings are essential for making informed investment and financing decisions. They play a significant role in ensuring market soundness and building trust among investors and consumers in sustainable finance. However, the risk of unintentional greenwashing arises when ESG ratings lack transparency or accuracy, leading to misaligned investments. To address this issue, the proposal aims to promote transparency and reliability in ESG ratings, ensuring that investors can make informed decisions about managing ESG risks and the impact of their operations.


The Proposal’s Scope and Application:

The proposal applies to publicly disclosed ESG ratings issued by EU rating providers distributed to regulated financial entities in the EU and certain public authorities. Private ESG ratings, in-house/internal ESG ratings and credit ratings would be excluded. ESG rating providers must be authorized by the European Securities and Markets Authority (ESMA) and follow various organizational requirements, processes and documents related to governance.


Supervisory and Authorization:

The ESMA is responsible for authorizing ESG rating providers and ensuring compliance with the regulatory framework. Therefore, the ESMA can withdraw or suspend authorization, impose fines or periodic penalty payments, request general information and conduct investigations and on-site inspections.


Enhancing the Transparency and Reliability of ESG

The proposal includes solutions to increase transparency and reliability in ESG ratings. ESG rating providers must be transparent and disclose information to the public about their rating methodologies, models and key assumptions. This includes assessing whether the methodologies are scientifically supported and whether the ratings evaluate risks and impacts or other relevant factors. Providers should also publish key information about ESG ratings and disclose detailed methodological information to subscribers and rated entities.

ESG rating providers must ensure the independence of their rating activities and avoid any political or economic influences or constraints. Additionally, providers are prohibited from providing consulting services to investors or undertakings. The proposal also aims to prevent conflicts of interest at the ESG rating providers’ level, ensuring a trustworthy market.


Preventing the Risk of Unintentional Greenwashing:

The proposal aims to improve investor protection, particularly for retail investors, by increasing transparency towards the public and reducing the risk of greenwashing. Market players risk unintentional greenwashing when ESG ratings lack transparency or accuracy, leading to misaligned investments. The proposal includes measures to prevent this risk, such as increasing transparency towards the public and improving investor protection.



The EU’s regulatory framework for ESG rating agencies is a significant step towards building a sustainable financial system. The proposal promotes transparency, reliability and independence in ESG rating agencies’ activities, ensuring that investors can make informed decisions about managing ESG risks and the impact of their operations. By doing so, it will help promote trust and confidence in sustainable finance and even support the transition to a more sustainable economy. The proposal is a positive development for the EU’s sustainability goals, and we look forward to seeing its impact on the financial sector.

For inquiries please contact:

RBI Regulatory Advisory

Raiffeisen Bank International AG | Member of RBI Group | Am Stadtpark 9, 1030 Vienna, Austria  | Tel: +43 1 71707 - 5923