The flow begins with First Order Codes, progresses to Second Order Themes, and then leads to Aggregate Dimensions. First, S F D R should define clear categories and Traffic light system could help differentiate products, which lead to Need for clearer differentiation and refinement of categories. Art. 9 is not always impact investing and Impact investors should be classified as Art. 9, which lead to Ambiguity between Art. 9 and Impact Investing. Superficial understanding of S F D R articles, Implementing S F D R is difficult and laborious, Uncertainty about possible changes to S F D R, and S F D R makes impact investing boring and bureaucratic, which lead to Uncertainty and structural complexity. These three themes then lead to Misalignment of S F D R structure and categorization. Next, Imbalance of disclosure requirements between S F D R Art. 8, 9 and Art. 6, Lack of clear definition and guidance gives rise to differing interpretations, and Need for flexible approaches, which lead to Misalignment of regulatory expectations and discrepancies in disclosure. Lack of resources for disclosure, Reporting under S F D R is expensive, Small investors are disadvantaged under S F D R, and Integration of S F D R into existing system can be problematic, which lead to Reporting hurdles and resource disparities. These two themes then lead to Perceived disproportionality in disclosure requirements. Next, Good data is a necessary condition for investment, Widespread comparable, reliable data is still lacking, Necessity to use proxies to fulfil S F D R requirements, and S F D R does not consider difficulties in collecting and measuring data from developing countries, which lead to Data quality and accessibility challenges. Measuring outcomes, Questionable relevance of S F D R metrics for impact investing, S F D R neglects social dimension, and Standardization under S F D R, which lead to Tension between standardized metrics and impact investing. These two themes then lead to Structural gaps in S F D R data and metrics. Next, Clarity and relevance of P A I s and S F D R should introduce a larger set of P A I s, which lead to Limited scope and clarity of P A I design. Achievements in transparency are questionable and Controlling the investee is difficult, which lead to Transparency limitations and restricted investor control. These two themes then lead to Limited effectiveness of P A I s in capturing impact dimensions. Finally, Microfinance industry had to develop best practices together and S F D R does not focus on intentional positive impact, which lead to Limited alignment with impact investing. S F D R achieved increased formalization and process optimization, Reduction of greenwashing, and Third party certification and legitimacy, which lead to S F D R achievements and remaining questions. These two themes then lead to Operational improvements despite strategic incoherence.Data structure
Source: Authors’ own work
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