• Article
  • ESG - Responsible Shareholders & Stakeholders
  • Codes & Regulations
Organisation type
  • Financial sector
  • Listed Company
  • SME

Initiative by Ministers Van Peteghem (Finance) and Khattabi (Climate, Environment, Sustainable Development and Green deal). 
Independent Consultancy Trinomics is leading the scoping project (start Oct. 2021- end July 2022) 
GUBERNA is one of the identified key stakeholders to get involved.  


In December 2021, GUBERNA received a questionnaire ordered by DG Reform (the European Commission’s Directorate-General for Structural Reform Support) with the goal to map the sustainable finance landscape in Belgium, in order to explore potential policy options for a Belgian strategy for Sustainable Finance.  

The questionnaire was divided into 4 main sections:

  1. introductory questions
  2. general questions
  3. specific questions primarily targeted at finance providers, recipients and intermediaries
  4. next steps of the consultation process

GUBERNA distributed this questionnaire amongst its members and received 30 answers from organisations active in various sectors. The majority of these organisations are private entities, with a few research institutions, NGOs and public organisations. The respondents could be ‘regrouped’ into three clusters: SME’s, large companies and financial actors (e.g. banks, asset managers, investment funds, insurance companies). 

The findings of the survey give a first insight into the state-of-the-art of the current landscape in sustainable finance and the issues that our member organisations are confronted with. However, the limited number of replies makes a further extrapolation or strong claims not opportune. As such, this summary must be considered as a pilot study and not a final report. 

Main findings 

What are the main opportunities of the sustainable transition of the financial sector in Belgium? What are the main reasons for the organisation to take ESG issues into consideration? 

Our respondents focused on financial and strategic opportunities when asked to identify the main opportunities of a transition to sustainable finance in Belgium. The answer “providing an enabling long-term policy framework that contributes to achieving environmental, social and governance commitments” was the most popular, but also “mitigating risks”, “fostering innovation and the use of new technologies” and “seizing business opportunities” are identified as drivers for transition.  

This is confirmed by a high score of “identifying growth opportunities” in answer to the question why the organisation would take ESG considerations into analyses/decision. Nevertheless, “regulatory requirements to consider ESG” scores equally high on that question, which means that internal drivers of transition are still highly complemented with an “external” stimulant. There is no observable difference between the environmental, social or governance aspects with regard to providing opportunities, they receive the same scores of high interest to consider them as objectives in financial strategies and decisions.  

In the comments it is indicated that the financial sector is the heart and engine of the transition, in its role to create awareness and to guide its clients towards their social responsibility, long term view, risk mitigation and creating a competitive environment. 

What are the main challenges of the sustainable transition of the financial sector in Belgium? What are the main obstacles for the organisation to take ESG issues into consideration? 

The main challenge identified in the transition to sustainable finance is the discrepancy between long-term investment strategy and short termism, as induced by the current financial system and market pressures, both aimed at achieving immediate performance.  

A second challenge is the administrative-heavy and complex regulatory framework, that is coupled with an insecurity on the “correct” quantification methodologies (leading to a risk of greenwashing). The complexity of regulation is also considered an obstacle for smaller organizations to estimate the impact of the transition. The access to sufficient high quality ESG data from ESG data providers is identified as one of the main obstacles to incorporate ESG in analyses/decisions, apart from the internal availability of operational data.  

What’s the situation? Level of readiness  

The respondents indicated an average level of readiness for the instruments within the EU sustainable finance framework. The EU Taxonomy Regulations as well as the upcoming instruments scored considerably lower: the Corporate Sustainability Reporting Directive (CSRD) and the EU Ecolabel for Retail Financial Products. However, there is a clear discrepancy here in answers from respondents from the financial sector and those of SME’s, where the scores of the SME’s are the lowest.  

The level of readiness can be related to the question of when the organisation started with considering ESG objectives as part of its financial strategies and decisions. Whereas social and governance considerations have already been considered 9-5 years ago, environmental issues just appeared for the last 2-4 years. This short time period is indicative for the crescendo of regulations that the organisations now face. In the comments it is indicated that the awareness phase just started, or that one or two initiatives or policies were just launched. Other organisations are clearly already much further, having implemented ESG in their core business strategies and KPI’s. The variation in answers is telling.  

Nevertheless, organisations clearly spend thought on how to incorporate ESG objectives in their financial analyses and decisions. The focus of the organisations is on climate change mitigation and reducing greenhouse gas emissions, circular economy and pollution prevention. For the social aspect, it’s about diversity, fair employment and Human Capital, health and safety and community relations. For governance, the role of the supervisory and managing bodies is of interest, just like business ethics and corporate culture as well as internal control.  

The preferred strategies to pursue ESG objectives is either to be best-in-class or to select a number of impact strategies, aimed at solving social or environmental problems. The double materiality perspective is well-known amongst the respondents, whereas scenario analysis is less popular. The respondents are looking for trustworthy ESG rating/scoring providers and are currently already using a number of different scorers. Labels are not yet commonly used or accepted. The “United Nations Global Compact” is the preferred international standard as tool for ESG analysis.  

Why are we not ready?  

The respondents indicated that on all sides, there are issues that hamper the readiness of the organisation. The main issue is the lack of sufficient human and financial resources needed to comply with the relevant regulations. These resources are of course a prerequisite, and without them, the lack of access to external data, the lack of knowledge about and lack of clarity on the EU instruments, the lack of clarity about the implementation timeline become problematic. On some of these points, there is again a clear discrepancy in the respondents from the financial sector compared to large companies and SME’s.  

The knowledge gap is the greatest on the upcoming regulations (CSRD and EU Ecolabel for Retail Financial Products) and is as such directly linked to the level of readiness to apply these regulations. The respondents indicate the gap on transversal awareness and standardisation, and the lack of exchange of best practices. The cost & time investment of applying the regulation is great.  

The knowledge gap is confirmed by the results on the question whether the respondents experience a data gap. In general, the availability of ESG data in the market in Belgium is rated as poor, and the comparability and reliability of the available data is considered very poor. There is no standard or uniformity, and particularly SME data is considered unreliable as a consequence of a lack of standard. The question is asked how banks can rate organisations that have not yet started reporting on sustainability. The lack of human resources with technical expertise is indicated. 

What can the government/regulator do?  

The respondents expectations toward the Belgian Federal government and/or the regulator are quite high regarding actions to be taken to facilitate and accelerate the sustainable transition of the financial sector (all suggestions, except for 2, received a high score in the questionnaire). However, priority is given to act as a role model, to create a strong and growing sustainable investments pipeline and to provide targeted measures at SMEs and smaller financial participants. 

In addition it is suggested that the government should steer and direct the change, by improving the financial information/reporting (access and quality), by providing incentives and the necessary tools and education, in particular for SME’s, to help these companies on board.  

A few conclusions 

  • The respondents are quite familiar with the concept of ESG, and aware of its importance and their role as (financial) organisations in the societal and environmental interests. 

  • They are aware that the regulations around the sustainable finance transition exist and that they have to be prepared. However, there is an observable difference between the financial sector and the large companies and the SME’s in the level of readiness. The financial sector wants to take the lead but needs sufficient support from the government and regulators.  

  • The greatest challenge the respondents perceive is to find enough (human & financial) resources to live up to the expectations of the government and the regulators. Besides, organisations are faced with large ESG data and knowledge gaps (in terms of availability, comparability and reliability). 


GUBERNA response to the questionnaire  

More information  

Prof. dr. Abigail Levrau (abigail.levrau@guberna.be

Dr. Saartje Verbeke (saartje.verbeke@guberna.be