Submission to the Australian Treasury's Sustainable Finance Strategy consultation

01 December 2023

To:
Sustainable Finance Unit
Climate and Energy Division
Treasury

RE: Sustainable Finance Strategy consultation

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to present its submission to this consultation.

The key points addressed in our submission are:

Pillar 1: Improve transparency on climate and sustainability 3

• Sustainability-related financial disclosures must include Scope 3 and influenced emissions
• Transition pathways should focus on short-term, material, credible outcomes
• A Sustainable Finance Taxonomy must be complemented by company-level assessments
• A sustainable investment product labelling regime should be challenging yet achievable, comprehensive yet clear

Pillar 2: Financial system capabilities

• There are still too many loopholes for companies to engage in greenwashing
• There is a strong case for regulating ESG ratings as financial services
• Various systemic risks must be addressed, such as rehabilitation liabilities, bottom-up overshoot and underreporting of methane emissions 
• Transparency is needed over reporting of key data

Pillar 3: Australian Government leadership and engagement

• More sustainable finance will be needed at household and SME level 
• Issuing Australian sovereign green bonds will be crucial to net-zero capital mobilisation
• The Clean Energy Finance Corporation will play a key role in catalysing sustainable finance flows and markets

Regards

Amandine Denis-Ryan – Chief Executive, IEEFA Australia
Saurabh Trivedi – Sustainable Finance Specialist
Anne-Louise Knight – Lead Analyst, Coal Industry Australia

To read the full submission click here.