The AMF is urging French stakeholdersโESG rating providers, users, and rated entitiesโto respond to ESMA's 2022 Call for Evidence on the EU ESG rating market to inform European Commission efforts on improving transparency and reliability. This matters as it contributes to the foundational data driving the ESG Ratings Regulation (EU 2024/3005), which imposes authorization, disclosure, and conflict-of-interest rules on providers, affecting sustainable finance compliance across the EU. With the regulation applying from 2 July 2026, early engagement helps shape final rules amid ongoing ESMA consultations on technical standards.
What Changed
This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companiesโelements now codified in the ESG Ratings Regulation effective 2 January 2025 (application from 2 July 2026).
Suggested Considerations
- For Users and Rated Entities: Although the 2022 Call for Evidence is closed, monitor ESMA's ongoing RTS consultations (closed 20 June 2025) and Commission feedback; assess internal ESG data reliance for SFDR/Taxonomy alignment and update policies for new disclosure requirements.
- All Affected Firms: Map ESG rating dependencies in investment processes, train compliance teams on upcoming rules, and engage in industry feedback to influence final RTS adoption expected post-Q4 2025.
- AMF Stakeholders: Although dated, the notice encouraged French market input; now pivot to compliance readiness for 2026 application.
Compliance Impact
Urgency: High โ The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026โless than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosures, and potential market disruptions if unprepared; non-compliance could halt EU operations or trigger greenwashing probes under SFDR, amplifying sustainable finance scrutiny.