Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency

The expansion of EU regulatory governance in the financial sector since the end of the global financial crisis 2008 has given rise to the need to examine regulatory consistency in the volumes of financial regulation that may have cross-cutting implications. In this light, this article examines the e...

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Main Authors: Iris H.-Y. Chiu, Herwig C.H. Hofmann, Felix Pflücke
Format: Article
Language:English
Published: Cambridge University Press 2025-03-01
Series:European Journal of Risk Regulation
Subjects:
Online Access:https://www.cambridge.org/core/product/identifier/S1867299X24000539/type/journal_article
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author Iris H.-Y. Chiu
Herwig C.H. Hofmann
Felix Pflücke
author_facet Iris H.-Y. Chiu
Herwig C.H. Hofmann
Felix Pflücke
author_sort Iris H.-Y. Chiu
collection DOAJ
description The expansion of EU regulatory governance in the financial sector since the end of the global financial crisis 2008 has given rise to the need to examine regulatory consistency in the volumes of financial regulation that may have cross-cutting implications. In this light, this article examines the effectiveness of the Regulation of ESG infomediaries through the lens of “functional regulatory consistency” with other infomediary regulations, for credit rating agencies and stock market benchmarks. It argues that this lens most aptly reveals the three key weaknesses of the regulatory regime for ESG infomediaries. These relate to sub-optimal coverage of scope, over-inclusiveness in the application of regulatory standards and under-inclusiveness where appropriate governance is not provided. the sub-optimal coverage of scope raises the question of whether ESG stock market index providers should indeed be regulated as ESG infomediaries or as stock market benchmarks more generally falling within the Benchmarks Regulation 2016. Over-inclusiveness and under-inclusiveness in the regulatory provision reflects blind spots in applying functional regulatory consistency, where it is inappropriate due to distinguishing features in business models, market structures or market relations.
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institution Kabale University
issn 1867-299X
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language English
publishDate 2025-03-01
publisher Cambridge University Press
record_format Article
series European Journal of Risk Regulation
spelling doaj-art-8d2f86a1dfeb4ce3b9d1cc4e469b9daf2025-08-20T13:03:13ZengCambridge University PressEuropean Journal of Risk Regulation1867-299X2190-82492025-03-011624226210.1017/err.2024.53Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory ConsistencyIris H.-Y. Chiu0https://orcid.org/0000-0002-3610-2047Herwig C.H. HofmannFelix PflückeFaculty of Laws, University College London, London, UKThe expansion of EU regulatory governance in the financial sector since the end of the global financial crisis 2008 has given rise to the need to examine regulatory consistency in the volumes of financial regulation that may have cross-cutting implications. In this light, this article examines the effectiveness of the Regulation of ESG infomediaries through the lens of “functional regulatory consistency” with other infomediary regulations, for credit rating agencies and stock market benchmarks. It argues that this lens most aptly reveals the three key weaknesses of the regulatory regime for ESG infomediaries. These relate to sub-optimal coverage of scope, over-inclusiveness in the application of regulatory standards and under-inclusiveness where appropriate governance is not provided. the sub-optimal coverage of scope raises the question of whether ESG stock market index providers should indeed be regulated as ESG infomediaries or as stock market benchmarks more generally falling within the Benchmarks Regulation 2016. Over-inclusiveness and under-inclusiveness in the regulatory provision reflects blind spots in applying functional regulatory consistency, where it is inappropriate due to distinguishing features in business models, market structures or market relations.https://www.cambridge.org/core/product/identifier/S1867299X24000539/type/journal_articlebenchmarkscredit ratingsESG ratingsstock market indices
spellingShingle Iris H.-Y. Chiu
Herwig C.H. Hofmann
Felix Pflücke
Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency
European Journal of Risk Regulation
benchmarks
credit ratings
ESG ratings
stock market indices
title Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency
title_full Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency
title_fullStr Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency
title_full_unstemmed Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency
title_short Regulating ESG Rating and Data Product Providers: Critically Examining EU Regulation through the Lens of Functional Regulatory Consistency
title_sort regulating esg rating and data product providers critically examining eu regulation through the lens of functional regulatory consistency
topic benchmarks
credit ratings
ESG ratings
stock market indices
url https://www.cambridge.org/core/product/identifier/S1867299X24000539/type/journal_article
work_keys_str_mv AT irishychiu regulatingesgratinganddataproductproviderscriticallyexaminingeuregulationthroughthelensoffunctionalregulatoryconsistency
AT herwigchhofmann regulatingesgratinganddataproductproviderscriticallyexaminingeuregulationthroughthelensoffunctionalregulatoryconsistency
AT felixpflucke regulatingesgratinganddataproductproviderscriticallyexaminingeuregulationthroughthelensoffunctionalregulatoryconsistency