With MiFID II provisions on integrating sustainability factors into product governance requirements (Delegated Directive (EU) 2021/1269) becoming applicable by 22 November 2022 at the latest, AMAFI has begun work with its members to consider the different problematic issues on this matter.

Thus AMAFI held several work meetings to highlight the difficulties arising, such as those associated with determining the ESG target market on the primary market or in the context of simple intermediation activities and to explore potential ways forward to find solutions. Proposals are being drawn up with a view to fuelling discussions at national level as well as AMAFI's future response to the consultation that ESMA is set to begin this summer on a new version of its guidelines on product governance requirements.