可持续金融转型基金策略的新兴趋势分析

Sustainable Finance Emerging trends intransition ESMA Report on Trends, Risks and Vulnerabilities Risk Analysis © European Securities and Markets Authority, Paris, 2025. All rights reserved. Brief excerpts may be reproduced or translated provided the sourceis cited adequately. Legal reference for this Report: Regulation (EU) No. 1095/2010 of the European Parliament and of the Council of 24 November2010 establishing a European Supervisory Authority (European Securities and Markets Authority), amending Decision No 716/2009/EC andrepealing Commission Decision 2009/77/EC, Article 32 ‘Assessment of market developments, including stress tests’, ‘1. The Authority shall monitorand assess market developments in the area of its competence and, where necessary, inform the European Supervisory Authority(EuropeanBanking Authority), and the European Supervisory Authority (European Insurance and Occupational Pensions Authority), the European SystemicRisk Board, and the European Parliament, the Council and the Commission about the relevant micro-prudential trends, potential risks andvulnerabilities. The Authority shall include in its assessments an analysis of the markets in whichfinancial market participants operate and anassessment of the impact of potential market developments on such financial market participants.’ The information contained in this publication, SustainableFinanceEmerging trends intransition Contact:guilain.cals@esma.europa.eu1 Summary New investment strategies have emerged that supportan economy-wide climate transition andcompanies in transition.As theEuropean Commission(EC)plans to review theSustainable FinanceDisclosure Regulation (SFDR),EU regulators have called for the creation of a transition productcategory2,where the focus is on investments in economic activities, assets or portfolios not yet Our main findings include: −Transition fundsprimarily define their ambition in terms of portfolio-level performance orexposure,which they sometimes complement with an ambition to foster real-economy −Positive screening of assets is informed by asset-level forward-looking data,in line with theECdefinition3 of transition investments,which refers to investments in activitiesexpected to −Positive screening appears to rely on the use of ESG ratings, but theroleof thoseratings isnotalwaysclear, due to limited disclosures by fund managers on the products used or the −To set targets andmonitor progress towardstransition funds ambition,the metrics most often −Data shows that transition funds have distinctive portfolio composition features compared withother environmental and ESG funds. They focus on equity instruments from energy-intensive -These characteristics suggest a more targeted and forward-looking investment approach, Introduction also seek to achieve realeconomy outcome,8based onpositive screening and engagement,therebyaddressing concerns about‘paper Withthe mainstreaming and maturing ofsustainable investingin Europesince 2020newinvestment strategies have emerged.Some ofthese strategies specifically aim to support an The EU regulatory framework already providessometools fortransitionminded investors. EUClimateBenchmarks support portfolio leveltransition,especially for passively managedfunds.Certain features of the EU sustainablefinance frameworkhelp companies communicate Outreachto industry participants and otherstakeholders5suggests that actively managedinvestmentfundswithclimatetransitionstrategies(hereafter referred to as‘transitionfunds’)generally rely on three main levers:positivescreening,negative screening andengagement.6Positive screeningofinvestmentsis usuallybased on anassessment oftransition-readinessor exposure tocertain activities (e.g.climatesolutionsorenablingactivities).Assessing transition-readiness usually involves Additionally,the ECpublished a recommendationto the marketin 2023,including adefinitionoftransition investments.11To harmonise namingpracticesandaddressconcernsaboutgreenwashing risks in the funds industry, ESMAissued Guidelines onESG-and sustainability-related terms infunds names. The Guidelines Yet,additional improvementswould helptomakesurethe frameworkmosteffectively supports thefinancing of theclimatetransition.13Amongsuchpossiblechanges, the ESAs have called for the Throughthese three levers,fund managerstypicallyseek toalign portfoliocompositionwithclimate-related objectives set at portfolio level. 10See ESRS E1-1, and the related disclosure requirements andapplication requirements, laid down in Commission DelegatedRegulation (EU) 2023/2772 as regards sustainability reporting 5Between May and July 2025, ESMA convened a series of threeworkshops on transition finance, with a view to support ESMA andNCAs’staff exposed to transition finance questions in theirsupervisionor regulation work and to foster supervisoryconvergence inthis nascent area.The workshops channelledinsightsfrom market participants and other stakeholders,regarding their currentpractic