Christian Heinz, Global Tax & Compliance Leader, PwC Luxembourg. (Photo: PwC Luxembourg)

Christian Heinz, Global Tax & Compliance Leader, PwC Luxembourg. (Photo: PwC Luxembourg)

EET, the European ESG Template, is expected to hit the asset management industry mid March 2022. Christian Heinz, Partner, PwC Luxembourg explains why market pressure will most likely lead to a de facto obligation to make this template available. Here, he shares information about the template and its development.

Are you aware and interested in the European ESG Template (EET)? If you are an asset manager, you should be.

It all starts with ESG, a measurable set of criteria that external partners and investors look at in their evaluation of a company. ESG illustrates a company's identification and quantification of its risks and opportunities, as well as highlights the ethics of a company. 

The template is being developed by the (Financial Data Exchange) working group, which started working on the template in April 2021. The final version was made available to the public on 14 March 2022. You can view the version on the .

FinDatEx is a joint structure established by representatives of the European financial services sector. It coordinates, organises, and carries out standardisation work such as technical templates to facilitate the exchange of data between stakeholders in application of European Financial markets legislation such as MiFID II, PRIIPs, and Solvency 2. The working group for the EET consists of 80 different people.

Investor Tax & Regulatory reporting. (Photo: PwC Luxembourg)

Investor Tax & Regulatory reporting. (Photo: PwC Luxembourg)

The template's main characteristics in a nutshell

The template is of interest to insurers, distributors, fund of funds, but also other financial market participants, financial advisors, fund managers.

It’s purpose is to serve as the standardised, machine-readable exchange template for ESG data as defined by the different EU regulations (SFDR, Taxonomy, IDD, MiFID). The population of fields follows in principle the same logic as other reporting templates.

For each field, the regulation to which it refers is indicated. For instance, in the case where you have only insurers as clients, you look at SFDR and IDD requirements; in the case where your clients are distributors only, you leave IDD aside; and if your clients are a mix, you refer to the column combining all regulatory requirements. The template contains the information needed in other reporting like the EMT, making this reporting “lighter”. There is a downside, though. If you populate e.g. an EMT, you have to populate an EET as well .

The scope is for all funds and structured products. For funds, the template should be provided on a share class level (ISIN level).

We’ve had a good look at the template, and it consists of 620 fields, being mandatory, conditional, and optional. The fields will change over time, meaning what is optional today might be mandatory in the future. Depending on the country of distribution, or the level of information needed, optional fields might be requested from the market.

All fields are pre-defined. No free text is foreseen in the template. To avoid many updates, all definitions are linked to the different regulations.

Mandatory and conditional fields have to be populated for Art 8 and Art 9 products. Other products have limited requirements at this stage. This means that, although it has 620 fields, only a limited number have to be populated for the 1 June 2022 exercise, when the template should be ready for first time reporting (for MIFID II and IDD). As from 1 January 2023, additional fields will become mandatory (SFDR related).  In terms of reporting frequency, at the beginning, an annual reporting frequency is foreseen.