ESG | Consob’s warning notice on ESG factors in investment funds issued

On 11 February 2024, Consob published a warning notice on the inclusion of ESG factors in the decision-making process of investment funds (OICR) and on the transparency of information at the product level by managers. The warning notice aims to guide the industry in the correct application of the existing regulatory provisions on sustainable finance and to provide useful indications for the convergence of supervisory activities in line with the initiatives launched by ESMA in this regard. Consob’s supervisory experience has highlighted key regulatory principles and identified examples of both good and bad practices with regard to pre-contractual and periodic product-level disclosures, as well as the incorporation of ESG factors in investment decisions. The document complements Consob’s earlier warning notice (No. 1/24 of 25 July 2024) on the compliance of funds to sustainable finance obligations in the provision of investment services. This latest notice, however, does not exhaust the issues worthy of attention, which, given the complexity and evolution of the subject, may further show up in the supervisory action.

Newsletter n. 105 – March 2025