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Mind The Gap: Challenges to Designing the EU Sustainable Finance Policy Mix


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Mind The Gap: Challenges to Designing the EU Sustainable Finance Policy Mix

Tessel C.C. Koopal 12438200

A thesis submitted in partial fulfillment of the requirements for the degree of

MSc Political Science Public Policy and Governance

Supervised by Dr. K.I (Kidjie Ian) Saguin

Second reader

Dr. R.M. (Rosa) Sanchez Salgado

June 2022







Finance can play a crucial role in the transition towards a sustainable world. In fact, it is estimated that 350 billion euros in sustainable investments from the private sector alone are needed to achieve the short-term objectives of the EU Green Deal. However, current efforts by the European Commission to spur this development are characterized by sub-optimal policy design because of incongruence between the goals and instruments of the EU Sustainable Finance Strategy policy mix. This thesis looks at what factors caused this incongruence to occur. Through interviews and document analysis, it finds that business stakeholders influenced the positive perceptual bias of policymakers which induced path-dependent policymaking. This led to the conversion of old instruments to new goals, which subsequently created incongruence between goals and instruments.

Keywords: Sustainable Finance, European Commission, Policy Mix, Path Dependence, Stakeholder Influence


Table of Contents

List of Tables and Figures... 4

List of Acronyms and Abbreviations ... 5

Introduction ... 7

Research Objective ... 9

Relevance ... 10

Thesis Structure ... 10

Chapter I – Theoretical Framework... 12

Sustainable Finance ... 12

Policy Mixes ... 15

Policy Design and Patterns of Change ... 17

Propositions... 18

Chapter II – Research Methodology ... 22

Research Question and Operationalization ... 22

Process-tracing ... 24

Chapter III – Emerging Incongruence ... 30

2018: EU Action Plan for Financing Sustainable Growth ... 30

2021: A Renewed Strategy ... 33

Current Policy Mix ... 35

Chapter IV – Path Dependence ... 45

Chapter V – Stakeholder Influence ... 47

Chapter VI – Strategic Mistake ... 57

Conclusion ... 61

A Framework for Incongruence ... 61

Contribution ... 62

Limitations ... 62

Avenues for Future Research ... 63

Looking Forward ... 63

Bibliography ... 64

Appendix I ... 69

Appendix II ... 70

Appendix III ... 75



I would like to express gratitude to my thesis supervisor Dr. Kidjie Saguin for his excellent guidance and contributions to this research project. Further, I would like to thank all the interview respondents for their time and willingness to engage in this project and their valuable insights. Last, but not least, I would like to thank all my peers in the RP Transformative Change and Governance of Wicked Problems for their continued support of one another throughout this process.


List of Tables and Figures

Figure 1. Building blocks of the extended policy mix concept……….….17

Figure 2. Stakeholder Map………28

Figure 3. HLEG’s (2018) Final Report Recommendations………...31

Figure 4. 2018 Action Plan on Financing Sustainable Growth………33

Figure 5. ‘Visualization of the actions’ – a demonstration of the policy mix………33

Figure 6. EU Sustainable Finance Policy Mix………..35

Figure 7. Six New Actions as Part of 2021 Renewed Sustainable Finance Strategy………….37

Figure 8. Stakeholder Consultation Number of replies by type of respondent……….49

Figure 9. Stakeholder Consultation Responses to Question 1……….49


List of Acronyms and Abbreviations

CMU Capital Markets Union

DG FISMA Directorate-General for Financial Stability, Financial Services and Capital Markets Union

EC European Commission

ECA European Court of Auditors

EFSD+ The European Fund for Sustainable Development+

EIP EU External Investment Plan ESG Environmental, Social, Governance

EU European Union

Eurosif European Sustainable Investment Forum HLEG High-Level Expert Group

IDD Insurance Distribution Directive

IPCC Intergovernmental Panel on Climate Change MiFID II Markets in Financial Instruments Directive II SDGs Sustainable Development Goals

SFDR Sustainable Finance Disclosure Regulation TEG Technical Expert Group

UN United Nations

UNEP United Nations Environment Programme


[intentionally left blank]



Sustainable Finance in Europe

Despite overwhelming scientific evidence on the detrimental effects of human activity on nature and the biosphere, public and private actors have not managed to curb the current global warming trajectory. As recently reaffirmed by the Intergovernmental Panel on Climate Change (IPCC), the human-induced effects of global warming and environmental degradation are creating unexpected changes in weather conditions, rising temperatures, and significant destruction to ecosystems (IPCC 2022: 11). Only a rapid global phase-out of anthropogenic greenhouse gas emissions will help to halt a literal further global meltdown (idem: 35).

Unfortunately, achieving the latter is a major challenge for societies around the globe as economic growth is still highly dependent on energy use powered by non-renewable energy sources (oil and gas) that emit harmful greenhouse gasses. This non-renewable energy dependency is rooted in our economic models that were designed in an age of resource abundance (Schoenmaker and Schramade 2019: 3). At that time—the onset of the Industrial Revolution in the 19th century—natural goods and services seemed unlimited and cheap labor was desirable to secure mass production (idem: 4). This created a destructive economic model that is no longer tenable, yet one that is still generally considered a necessary condition for societies’ welfare (ibid.).

However, it is increasingly recognized that a transformation away from old economic practices and towards a more sustainable world will be necessary if we want to protect life on earth as we know it. Hence why the concept of sustainable development (or sustainability) has experienced an unprecedented boom in recent decades (Kiss 2011: 1). As an umbrella term, sustainable development stands for the belief that human activities need to be in such a manner that they can meet the needs of the present without compromising those of future generations (Schoenmaker and Schramade 2019: 3). Sustainable development has historic roots in environmental protection, but since the United Nations (UN) launched the Sustainable Development Goals (SDGs) it is also often referred to in a social and economic context.

Environmental sustainability concerns issues like climate change, appropriate land use, and biodiversity. On the social and economic front, sustainability is about ensuring people live above certain minimum social standards (ibid.). Sustainable development, therefore, comprises both improving the lives of humans on earth as well as mitigating the dangerous effects of human activity on earth (UN n.d.).


A sector that has experienced such a booming interest in sustainable development is the financial sector. The renewed focus on sustainable finance is interesting as the financial system in principle is rooted in the dominant economic system that prefers profit over the planet.

However, since the main task of finance is to allocate funding to its most productive use, there is great potential for the financial actors to guide investments towards more sustainable corporations and projects (Schoenmaker and Schramade 2019: 4). As Christine Lagarde stated at the launch of the COP26 Private Finance Agenda in 2020: “By shifting the horizon away from the short term and contributing to a more sustainable economic trajectory, the financial sector can become a powerful force acting in our collective best interest” (Lagarde 2020). The financial system can therefore help accelerate a transition toward a fair and low carbon economy.

In light of this critical role, it is unsurprising that European Commission (EC) policymakers established an EU sustainable finance agenda as a key element of the broader European ‘green’ growth strategy: the EU Green Deal (EC 2019). After all, broad considerations guide the development of goals while funding is necessary to achieve those goals. However, the magnitude of the EU Green Deal’s investment challenge cannot be met by public funds alone and requires the private sector to scale up investments into sustainable projects. The EC established that to achieve the EU Green Deal’s 2030 targets, 350 billion euros of annual investment in the energy system alone will be required (EC 2021a: 1). This is an amount equal to about 2% of the EU’s 2021 GDP1. In addition, to meet all short- and long- term targets, some have even estimated that a total gap of 2.5 trillion euros will have to come from the private sector (Brühl 2021: 324). The sheer size of this funding gap demonstrates that private finance—despite it not being the single panacea—is a necessary condition for a successful transition towards a sustainable future.

In 2021, the EU Sustainable Finance Strategy was therefore established as a key guiding framework to redirect private finance toward sustainable investments. The strategy builds on three separate goals and various instruments to achieve the larger policy objective of raising the enormous amount of capital to achieve the goals of the transformative EU Green Deal.

However, closer examination of the strategy reveals that there are issues with the design of the instruments. A report by the European Court of Auditors (ECA 2021a) found that the current strategy is not sufficient to stimulate sustainable investments. “The EU’s actions on sustainable

1 Total Gross Domestic Product (GDP) of the EU in 2021 was 14.45 trillion euros. See:



finance will not be fully effective unless additional measures are taken to price in the environmental and social costs of unsustainable activities,” said Eva Lindström, Member of the ECA (EC 2021b). This is because the EC designed instruments focused on increasing transparency in the market. Although this is an important condition, it is not sufficient to force the necessary allocation of capital toward sustainable projects. As Lindström further stated:

“Unsustainable business is still too profitable. The Commission has done a lot to make this unsustainability transparent, but this underlying problem still needs to be addressed” (ibid.).

Research Objective

While the EU has demonstrated ambition to engage in transformative change through the EU Green Deal, issues have been raised against the ability to achieve these goals. This is because the Sustainable Finance Strategy as a key component of the EU Green Deal includes instruments that are not designed to meet the transformative EU Green Deal objectives.

Considering the widely recognized urgency to solve the current challenges and the EU’s demonstrated ambition to do so, it is striking that EC policymakers did not design and implement more appropriate instruments to achieve the transformative goals. Therefore, the question guiding this research is: Why is there an incongruence between the goals and instruments of transformative sustainable finance policy mixes?

In attaining an answer, this research challenges the rational policy-making assumption that goals and instruments are always in congruence and that policymakers constantly seek to design policy (mixes) optimally. Guiding the analysis will be the following sub-questions that seek to explain what factors may have created the incongruence of the sub-optimal EU Sustainable Finance Strategy policy mix: 1) In what context did the policy mix emerge and develop? 2) What patterns of change can be identified as part of the emergence and development? 3) How does path dependence shape patterns of change? 4) How does stakeholder influence shape patterns of change?

The discussion is developed in light of insights gained through a process-tracing analysis of five (elite) interviews and a document analysis. Results of this research demonstrate a framework that connects stakeholder influence with positive perceptual biases that cause path dependence within processes of policy change, which can create incongruent policy mixes for sustainable (financial) change.



It is extremely relevant to study how policy mixes may be designed in a sub-optimal fashion because the policy mix concept is increasingly recognized by policymakers as a holy grail to tackle complex issues like sustainable transformations. Highlighting how certain factors can influence the design of such mixes is therefore important. This paper may serve as a learning tool for any policymaker who designs or amends policy mixes for sustainable transitions, and beyond. In addition, the topic of sustainable finance is a fast-growing concept that is increasingly embraced by public and private actors as a key green strategy. Although that is good if executed well, highlighting that those strategies may also be flawed is important for actors within the financial sector and the public realm to avoid greenwashing2.

The case of the EU Sustainable Finance Strategy was selected for specific reasons.

This is because the EC is currently the most ambitious legislative body in the world with regards to creating a sustainable finance regulatory and policy environment in the form of a policy mix. If done well, the EU has the potential to become a global standard setter for this type of legislation in other parts of the world. However, while trying to govern bloc-wide regulatory commitment, the EC must balance the sovereign interests of Member States and that of many other actors. Observing pitfalls and weak spots within the framework is therefore telling for future regulatory (sustainable finance) initiatives in other regions, such as the US, ASEAS, or Mercosur.

Thesis Structure

The first chapter of this thesis outlines the theoretical framework that underscores the significance of the subsequent empirical analysis. It illustrates previous academic debates regarding the concepts of sustainable finance and policy mixes as well as the theory guiding the propositions that seek to answer the research puzzle. After having established the theoretical context in Chapter I, Chapter II will highlight the methodological approach used to answer the research question and sub-questions. Moving to the more considerable part of this thesis, Chapter III will outline the incongruent characteristics of the EU Sustainable Finance Strategy, and those of the policymaking processes of change that gave rise to it. Following this, Chapter IV will establish how path dependence bias shaped the processes of change and the incongruence. Chapter V then highlights how stakeholder influence shaped the bias among

2 Greenwashing is the selective disclosure of positive information without full disclosure of negative

information so as to create an overly positive corporate image (Lyon and Maxwell 2011). It is often used when companies are accused of pretending to be ‘greener’ than they actually are.


policymakers. This is followed by a nuanced perspective on motivations for influence in Chapter VI. Closing remarks on these findings alongside limitations and recommendations for future research are discussed in the conclusion.


Chapter I

Theoretical Framework

While the EU Sustainable Finance Strategy is increasingly being cited as a potential trailblazing framework for a sustainable (finance) transition, there is surprisingly little research on the policy design principles upon which this complex framework is built. Yet, policy design is the process in which policy actors try to “more or less systematically develop efficient and effective policies through the application of knowledge about policy means gained from experience, and reason, to the development and adoption of courses of action that are likely to succeed in attaining their desired goals or aims” (Capano and Howlett 2015: 1). Therefore, analyzing the structures and processes of the policy design can advance the understanding of whether the ambitious EU agenda will fill the gap to accomplish the sustainable transition.

This chapter will first illuminate the fragmented conceptual landscape of the sustainable finance terminology and scope out the most appropriate definition of sustainable finance with regard to this thesis research. It will then discuss the concept of policy mixes and highlight how certain patterns of change may have influenced the design of the incongruent policy mix.

Finally, it will outline the key propositions of the proposed framework in this thesis.

Sustainable Finance

Considering the supposedly critical role of the financial sector in supporting wider sustainable development goals, the concept ‘sustainable finance’ has received a lot of attention in both academic research as well as the financial sector. However, in both contexts, a clear and pervasive definition of what exactly constitutes sustainable finance has been lacking. This gap in conceptual clarity has rendered it difficult to identify what practices exactly count as sustainable finance. This can ultimately impede a successful transition towards a financial system that operates within planetary boundaries.

Despite its recent growth in popularity, the concept of ‘sustainable finance’ has been around for quite a few decades. However, as Migliorelli (2021: 1) noteworthily stated, the sustainable finance landscape as it stands today is characterized by an overabundance of definitions. Since the 1970s, people have used a wide array of different terms to refer to what this paper considers ‘sustainable finance.’ In their review, Cunha et al. (2021) map this terminological development. Before the 1970s, there was no specific term attached to sustainable finance investment, yet investors—mostly religious entities or churches—did impose restrictions on investment activities that were not aligned with certain ethical codes


such as stocks from alcohol or tobacco companies (idem: 3825). In the 1970s, socially responsible investment came around. This largely focused on investing in companies that were supporting social movements such as the anti-Vietnam War or the apartheid regime in South Africa. In the 1980s, social investment and ethical investment emerged and the first funds with these labels gained momentum. These funds were created to address certain societal concerns such as human rights, gender equality, and sexual diversity (ibid.). In the 1990s, green investment/finance came around as the environmental dimension became more important.

Social and environmental aspects were then grouped into one with responsible investment, and impact investment and microfinance became increasingly more popular (ibid.). Starting in the 2010s, climate finance entered the stage. This specifically focused on investments and financial services that contribute to the mitigation of and adaptation to global climate change. This is similar to low-carbon investment/finance. At the same time, blue finance also emerged, which is focused on financial resources for ocean conservation. ESG investment highlights environmental, social, and corporate governance components in investment strategies. And finally, sustainable finance/investment addresses all the long-term challenges related to sustainable development (ibid.). In addition to all these terms, Eccles and Viviers (2011: 389) found that more obscure terminology has also been used to refer to sustainable finance concepts, including community investing, faith-based investing, and environmentally responsible investing.

Although all the previous terms seek to describe financial and investment activities that have a positive social and environmental impact, the excessively sporadic use has made it difficult to identify the most important actors, their focus areas, roles, and strategies. Within academic literature, the definitions have therefore largely been based on the researcher’s underlying motivations and perspectives of what sustainability constitutes. For instance, Urban and Wójcik (2019: 2) held that sustainable finance is “finance that protects the fundamental right of all human beings to an environment adequate for their health and well-being and safeguards inter-generational equity.” Whereas Brühl (2021: 4) stated that sustainable investments are “investments that seek to contribute towards sustainable development by integrating long-term ESG criteria into investment decisions.”

Some have argued against the idea of unifying the term sustainable finance because rigorously defining sustainable finance and related terms and concepts could lead to the idea that it is still a niche market concept and that seeking a homogenous definition is impractical given that sustainable development is an evolving concept (Höchstädter and Scheck 2015;


without a clear definition of what can be considered sustainable, there is a significant risk of wrongly identifying activities as sustainable – or greenwashing (EC n.d; Sandberg et al.


In a more practical context, this sporadic use has also occurred. Financial institutions, governments, and international organizations have applied different terms interchangeably and given them different definitions based on their underlying motivations (Migliorelli 2021: 1).

For instance, the World Economic Forum (Fleming 2020) defined green finance3 as “any structured financial activity that has been created to ensure a better environmental outcome”, whereas the United Nations Development Programme (UNEP n.d.) defined green finance as

“to increase the level of financial flows (from banking, micro-credit, insurance, and investment) from the public, private and not-for-profit sectors to sustainable development priorities.” This is another example of conflicting definitions because WEF considers ‘green’

to be only environmental in scope, whereas UNEP uses ‘green’ to refer to broader ‘sustainable development priorities.’

To establish clarity in this conceptual fuzziness, this thesis will be aligned with the definition as established by the EC (2018a: 2). Their definition of sustainable finance is: “the process of taking due account of environmental and social considerations in investment decision-making, leading to increased investment in longer-term and sustainable activities”

(ibid.). This is the definition upon which the EC built the instruments of the Strategy. Given that this research seeks to trace the EC agenda-setting and policy design process of those instruments, it is most appropriate to use this definition to avoid potential gaps in terminological meaning. In addition, this is the most conceptually grounded definition because the EU Taxonomy instrument defines all activities that are considered (environmentally) sustainable. Scholars like Brühl (2021: 4) and the G20 Green Finance Study Group (G20 2016:

3) have also embraced this definition.

Further, this thesis follows Migliorelli’s (2021) policy-driven classification framework of sustainable finance and its main components. This framework has established that sustainable finance first and foremost embraces financial stocks and flows mobilized to achieve the SDGs. Although frequently used interchangeably, this framework (and therefore this paper) considers green finance and climate finance as subsequent components of sustainable finance.

In the framework, Migliorelli (2021: 5) also argued that sustainable finance may include financial stocks and flows that contribute to sustainable development that are not (yet) covered

3 Note that the terms sustainable finance and green finance are frequently used interchangeably.


by the SDGs, such as combatting the weakening of democracy aided by Big Tech. Given that this thesis is in the context of the EU, it will follow the EU Taxonomy guidelines on which (environmental) activities can be considered sustainable.

Policy Mixes

The EU Sustainable Finance Strategy objectives have resulted in multiple actions that aim to achieve the policy goals formulated by the strategy. They collectively form what is referred to as a policy mix. Policy mixes have been a growing concept in academic literature regarding policies and politics of transitions and are frequently proposed as a solution to the complexity of many sustainability problems. (Rogge and Reichardt 2016: 1621; Howlett and Rayner 2007:

1; Rogge et al. 2017: 2).

Defining Policy Mixes

The most basic definition of a policy mix is that it is a combination of different policy instruments (Lehmann 2010; Matthes 2010). Policymakers have held that combining different policy instruments will attain goals more effectively and efficiently than using one single silver bullet instrument (ibid.; Gunningham et al. 1998). However, there has been debate about whether a combination of policy instruments’ is an accurate description of policy mixes. In their thorough analysis of policy mixes for sustainability transitions, Rogge and Reichardt (2016: 1621) stated that using that definition refers more to an instrument mix than a policy mix. They argued that such a basic definition fails to address the complexity and dynamics of real-world policy mixes.

Similar to the sphere of sustainable finance terminology, definitions of policy mixes have been sporadic and are largely dependent on the scientific field. In specific, three key disciplines have centered around the concept of policy mixes within academic literature:

environmental economics, innovation studies, and policy sciences (Rogge et al. 2017). These fields have largely developed separate from each other and created a variety of perspectives about what a policy mix is and in what key terms it should be defined (idem: 2).

In environmental economics—the study of empirical or theoretical effects of environmental policies on the economy—research has focused on studying the advantages and disadvantages of using different combinations of policy instruments and their interactions (ibid.). The focus has been on finding optimal combinations of policy instruments and addressing failures and successes of policy instrument and tool combinations. Second, the field


of innovation studies has taken an interest in policy mixes as a tool for promoting technical or other innovations. Scholars in this field have adopted a broader perspective that looks at instrument interactions but also finds policy processes, targets, and policy coordination challenges important to consider (ibid.). Rogge and Reichardt (2016: 1625) argued that a broader perspective is particularly relevant for innovations for sustainability transitions. Third and last, the field of policy analysis has focused on the overall policy mix characteristics (Rogge et al. 2017: 3). This goes beyond instrument consistency and interactions and additionally considers congruence between instruments and goals. The latter is often in the context of multiple governments and governmental actions over time (ibid.).

Despite the terminological variety, the perspectives from all three fields indicate that there is more to a policy mix than it only being a combination of instruments and that particularly external factors can influence the effectiveness of a policy mix. Given that this research also seeks to address real-world intricacies that may influence policy mixes for sustainable transitions, it follows the definition from Kern and Howlett (2009: 395) that policy mixes are “complex arrangements of multiple goals and means.” This definition is in line with both the field of innovation studies as well as policy sciences. Goals can be defined as “strategic targets defined by policy actors” and means refers to policy instruments deployed to achieve those goals (Nilsson et al 2012: 397).

Policy Mix Framework

This paper will analyze the broader dynamics of policy mixes. In doing so, it will use Rogge and Reichardt’s (2016) framework consisting of three building blocks: elements, processes, and characteristics (See Figure 1). The elements block comprises a policy strategy, the instruments to achieve the strategy, and the mix of instruments (idem: 1622). The content of the element block is the result of the policy processes block which consists of policy implementation and policy making (ibid.). The third block is the characteristics to define the processes and elements, such as coherence, credibility, and comprehensiveness. Those are influenced by dimensions such as geography, time, and governance level (ibid.).


Figure 1: Rogge and Reichardt’s (2016: 1629) Building blocks of the extended policy mix concept


Policy Design and Patterns of Change

Rarely ever are entire policy mixes designed and implemented at once. Instead, they develop over relatively long periods and contain policy instruments that are stacked as policymakers try to expand on certain objectives or experiment with new instruments (Howlett and Rayner 2007: 1, 7). While changing the policy mix, the general goal for policymakers is always to ensure that there is an underlying overall logic in the design and that the policy mix is therefore in optimal shape. Analyzing the patterns in policy (mix) change is therefore important when trying to establish how relationship issues between goals and instruments of policy mixes may occur.

A lot and at the same time very little are known about how change occurs. With regards to policy change, Bennet and Howlett (1992) described it as incremental shifts in existing structures or new and innovative policies. It is different from policy reform as this is the process of improving the performance of existing systems and of assuring they are efficient and equitable in response to future changes (ibid.).

In their analysis of ‘New Governance Arrangements’ (or policy mixes), Howlett and Rayner (2007) establish four institutional trajectories that portray the types of evolvements of a policy mix’ goals and instruments. These four patterns of change are ‘layering’, ‘drift’,

‘conversion’, and ‘replacement’ (idem: 8). Layering is the process whereby new elements are added to an existing regime without abandoning previous ones. Drift occurs when the elements of a policy mix are deliberately maintained while the policy environment changes. Replacement is when instruments are replaced by others and are considered the least constraining for successful design. Lastly, conversion involves holding most of the policy instruments in place while redeploying the mix to serve new goals (idem: 8–9).


It is important to consider these four types of change as there has been a strong tradition in design literature to restrict discussion of design and change to situations characterized by processes of replacement and exhaustion. When in fact, layering, drift, and conversion are closely related to replacement, exhaustion, and each other. For instance, layering of new instruments and goals without abandoning old ones can open space to link to new goals and therefore induce conversion (Howlett and Rayner 2013: 177).


To explore how patterns of change may occur and cause an incongruence, this research draws from three separate propositions that current literature offers.

Proposition 1: Path dependence

Path dependence is frequently related to the question of change (or lack thereof). With regards to policy change and patterns of change, path dependence is usually considered a factor for policy continuity and a cause for resistance to change. The methodology section of this paper will highlight how path dependence can be established.

First, it is important to illuminate the conceptual background of path dependence. It is increasingly recognized that governing a sustainable transition does not start with a clean slate but is embedded in pre-existing policy contexts with legacies of policy instruments from earlier eras (Kern and Howlett 2009; Rogge et al. 2017: 2). In light of this, path dependence has become a widely used concept in social sciences and it has been given several interpretations depending on the field of research. Within historical institutionalism, the central claim on path dependence is that ‘history matters.’ This refers to the idea that formations that are put in place in the early stages of an institutional or policy life effectively constrain activity after that point (Greener 2005: 62; Sewell 1996). However, other scholars have argued that path dependence means that once a country or region has started down a track, the costs of reversal are very high and therefore other choices are obstructed (Levi 1997). This definition is largely centered around costs. Arthur (1989; 1990; Arthur et al.: 1983) stated that in path-dependent situations, there are first multiple possibilities of which a few are then sensitive to the ‘initial conditions of the political situation that created the policy or institutions. This creates positive feedback mechanisms that ‘lock in’ those possibilities and favors them over others that may be more optimal. The flaw in this conceptual clarification is however that if positive returns were to dominate a system for a considerable period, it would eventually remove all opposition and take away the opportunity for a change completely.


In the context of the EU Sustainable Finance Strategy, path dependence as a result of technological innovation or significant high costs is not the most feasible explanation.

Therefore, this paper considers what Lee and Gloaguen (2015: 95) referred to as “positive perceptual biases” that limit future choices. This definition is better suited because EC policymakers may have positive experiences with implementing previous transparency and disclosure requirements and therefore find it more doable to pass those kinds of instruments as opposed to new ones that would generate more resistance from less ambitious actors.

Besides defining path dependence, it is also important to establish how path dependence within policy mixes may occur. Kotilainen et al. (2019) and Seto et al. (2016) found that institutional lock-in and behavioral lock-in are processes that can lead to path dependence.

Institutional lock-in can arise because institutions are “distributional instruments laden with power implications” and therefore largely arise due to conscious efforts by powerful economic, social, and political actors (Seto et al. 2016: 433). These actors engage in intentional and coordinated ways to structure institutional norms, processes, and rules and promote their own goals. Often, powerful interests tamper down any disruptive change and try to defend a certain status quo. Therefore, to analyze institutional lock-in it is important to consider how vested interests and power asymmetries are represented (idem: 433-34; Kotilainen et al. 2019: 578- 9). Another cause for path dependence is behavioral lock-in. Research on behavioral path dependence has found that this process has to do with “irreversibility due to learning and habituation” (Kotilainen et al. 2019: 579). There are multiple aspects to behavioral lock-in including individual decision-making and social structural behaviors. The first has been largely developed through rational choice theory which argues that individuals can have certain habits that are hard to overcome (Seto et al. 2016: 438-9). The second considers socially shared practices, routines, and norms that coevolve with technologies, infrastructures, social networks, markets, policies, and cultural norms in place (idem: 440). For instance, policymakers or other actors can develop an attachment to certain products or processes even when better alternatives exist (Kotilainen et al. 2019: 578–9).

Proposition 2: Stakeholder influence

The second proposition is the concept of stakeholder influence. Within any public policymaking context, the engagement of multiple stakeholders with different and sometimes conflicting interests is present. While recognizing that this concept is closely related to institutional lock-in (due to vested interests and power dynamics), this paper considers it as a


separate approach to also analyze if any particular type of stakeholder exerted dominant influence or interference with the EU Sustainable Finance Strategy.

The theory of stakeholder influence is closely related to the phenomenon of interest group influence. Most academic literature regarding this proposition is largely dominated by Olson’s classical rationale that asserts that between types of interest groups, private business sector interest groups tend to have the upper hand (Lowery 2015: 9). In the years following, this narrative has been confirmed by Salisbury (1984) who found that business had the largest part of interest groups in the U.S, Aizenberg, and Hanegraaff (2019) who found similar patterns in Great Britain, and Schneider and Baltz (2003) who found that private sector interest groups in Germany and the Netherlands also had privileged positions in the pre-negotiations phase of legislative proposals by the European Commission. Additional scholars like Dür & De Bièvre (2007) and Streeck and Schmiter (1991) also affirmed the idea of dominant corporate influence.

Zooming in on the EU legislative process, it is widely acknowledged that business stakeholders have always strongly attempted to influence EU policymaking. This is predominantly because as an economic and trade bloc, the EU institutions legislate many aspects of business and therefore those groups often have high stakes (Dür et al. 2015: 952).

Considering this dominant influence, Dür et al. (2015) analyzed more specifics behind business group ‘wins’ in the EU. They found that business groups often defend the status quo because most new EU legislation concerns more market regulation and that is often not popular among business sectors. In addition, their research found that the success of defending the status quo is largely based on whether business receives support from elite circles involving few interest representatives and executive officials. In the EU, this means that there are low levels of controversy and that the role of the European Parliament is limited (idem: 967). This means that business groups have more success in the context of bureaucratic policymaking. However, this research is centered around the decision-making phase of the legislative process. Klüver (2013) concluded that business can be very successful in affecting the EC’s policy plans earlier in the agenda-making process.

In more recent literature, Hanegraaff and Poletti (2021) also found that the relative share of contacts between firms and EC staff has increased over time. This suggests that firm lobbying has indeed increased in the EU political system. There are therefore sufficient theoretical grounds to suggest that business lobbying may have influenced EU policymakers’

policymaking on the sustainable finance agenda.


Proposition 3: Strategic policymaking

The third proposition that may explain why the policy mix has a sub-optimal policy design is much more optimistic and characterized as strategic policymaking.

Past climate and energy policies have demonstrated that the public and private sectors are not always on the same page about the urgent necessity to act upon climate change.

Unfortunately, the wicked nature of the problem requires most, if not all, actors to reduce carbon emissions to have real effective change. Therefore, the third proposition is based on previous literature that has explained how policy mixes for sustainable transition in the EU have served as a strategy by the EC to promote political feasibility and transition functions, even when there is initial opposition from the least ambitious member states (Skjærseth 2021).

This proposition fits within Rogge and Reichardt’s (2016) notion that policy strategies are also part of a policy mix and therefore demand increased attention to the underlying

“political problem-solving process among constrained social actors in the search for solutions to societal problems – with the government as a primary agent taking conscious, deliberate, authoritative and often interrelated decisions” (idem: 1625).

The EC has a unique role in policymaking due to its ability to propose new EU legislation without being responsible for the financial resources needed at the member-state level to implement those policies. Thus, the EC’s strength is its capacity to shape and frame policies for the longer term without facing some of the short-term constraints that the Member States often do (idem: 31). Skjærseth (2021) found that the EU has used this policymaking capacity to create energy and climate policies that strategically drew in the least ambitious actors by promoting policies that appealed to them. From there, positive policy feedback allowed for more ambitious targets.

It could be that the EC first implemented a policy mix package that focused on disclosure and transparency because it was the only policy mix that would be accepted by the least ambitious actors. The hope is maybe that transparency and disclosure will have positive policy feedback effects that will allow for more rigorous policies in the future.


Chapter II Research Methodology

To adequately answer the research question, this paper has chosen to rely on qualitative research methodologies. The chapter will first discuss the research objective and case selection.

It will then elaborate on the selected answering approaches of process-tracing of (elite) interviews and document analysis. Triangulation of these methods accounts for the weaknesses of each method and a reduction of validity threats. Next, the interviews and data sources used for process tracing will be discussed in light of their relevance to the research objective.

Research Question and Operationalization

By focusing on the EU Sustainable Finance Strategy, this research aims to expose policy design and policy change issues of policy mixes for sustainable transformations. The overarching research question is, therefore: Why is there an incongruence between the goals and instruments of transformative sustainable finance policy mixes? More specifically, the sub- questions will inquire to analyze 1) In what context did the policy mix emerge and develop? 2) What patterns of change can be identified as part of this emergence and development? 3) How does path dependence shape patterns of policy change? 4) How does stakeholder influence shape patterns of policy change? Together this will provide the guiding thread to analyze how the EU Sustainable Finance Strategy policy mix came about and evolved into what it is today.

As explained in the literature review, the operationalization of these questions will be guided by the extended framework for policy mixes as established by Rogge and Reichardt (2016). Therefore, in addition to the definitions of sustainable finance and policy mix, the concepts described below will also be used that define the three building blocks of policy mixes: elements, policy processes, and characteristics, and explain what it means to have incongruence between goals and instruments of the policy mix.

The elements building block consists of policy strategy which is defined as a combination of policy objectives and the principal plans for achieving them. Policy objectives are long-term targets with quantified ambition levels. Principal plans are the plans to achieve these objectives (idem: 1623). They generally outline a path that will attain the objectives.

Instruments is another key element of the policy mix and constitute the concrete tools to achieve the overarching objectives and goals. They are tools and techniques of governance and there can be different types of instruments. The combination of different instruments can be defined as an instrument mix (ibid.).


The second building block is the policy processes which is defined as a “political problem-solving process among constrained social actors in the search for solutions to societal problems – with the government as a primary agent taking conscious, deliberate, authoritative and often interrelated decisions” (idem: 1625). The processes are significantly influenced by the interplay between power, agency, and politics. They cover all stages of the policy cycle, including problem identification, agenda-setting, policy formulation, legitimization and adoption, succession, and termination. The two components of policy processes are policy making and policy implementation. Policy making speaks for itself but has two important features, namely 1) policy learning, which is the monitoring and evaluation of the impacts of policy mixes—often through participatory processes of envisioning, negotiating, learning, and experimenting—and 2) that the process is often highly political and characterized by resistance to change (ibid.). Policy implementation refers to the process of executing and enforcing the policy instrument mix. Lastly, the style of policy processes can also be important as it illustrates the operating procedures for making and implementing the policies (ibid.).

The third block refers to the characteristics of the policy mix (idem: 1626). Consistency of elements captures how well the elements of the policy mix (mostly instruments) are aligned with each other and contribute to achieving the policy objectives. In other scholarly literature on the design of policy mixes, consistency has been referred to as the ability of multiple policy tools to reinforce rather than undermine each other in the pursuit of individual policy goals.

There are three levels of consistency. First, consistency of the policy strategy refers to the alignment of the policy objectives meaning that they can be achieved simultaneously without undermining each other. Second, consistency of the instrument mix refers to the ability of multiple policy tools to reinforce rather than undermine each other in the pursuit of individual policy goals (Howlett and Rayner 2013). Third, the consistency between the interplay of instrument mix and policy strategy to work together in a supportive manner, thereby contributing to the policy objectives (ibid).

Second, coherence of processes refers to synergistic and systematic policy making and implementation, or in other words the ability of multiple goals to co-exist with each other logically (ibid.). Third, comprehensiveness refers to how extensive and exhaustive the elements of the policy mix are and to which degree its processes are based on extensive decision-making (idem: 1627). This can be evaluated by considering whether a policy mix consists of a policy strategy, with objectives and principal plans and at least one instrument to operationalize this strategy. Fourth, credibility refers to the extent to which the policy mix is believable and


leadership, operationalization of targets by a consistent instrument mix, or delegation of certain competencies to independent agencies (ibid.).

The characteristics of the mix are closely related to what Howlett and Rayner (2013) defined as the evaluative criteria to consider when analyzing the design of policy mixes and all the above-mentioned components of such design. In addition to the above-described concepts of consistency and coherence, they also added the label of congruence. This refers to the ability of multiple policy goals and instruments to work together in a mutually supportive fashion and is conceptually similar to Rogge and Reichardt’s (2016) consistency of the interplay between instrument mix and the policy strategy (idem: 1625). Therefore, when this research refers to (in)congruence, this interplay between instruments and objectives/goals is analyzed.

Furthermore, the framework also has a dimensions aspect that specifies all three building blocks and is important when considering the context of policy mixes. Dimensions can be distinguished by policy field, governance level, geography, and time. The specific operationalization of the concepts of path dependence, stakeholder influence, and strategic policymaking is outlined in the research operationalization guide (see Appendix III). See Figure 1 for a structural overview of the framework.


To establish the policy mix and the incongruence between goals and instruments, this research will rely on a qualitative process-tracing methodology.

Process-tracing is a method for “identifying steps in a causal process leading to the outcome of a given dependent variable of a particular case in a particular historical context.”

(George and Bennett 2005: 176) In this research, the dependent variable is the EU Sustainable Finance Strategy policy mix and the outcome of this variable is the incongruence between goals and instruments. “Tracing the steps in the causal process” is analyzing which instruments were designed and how they interact and relate to the established goals, and investigating the processes, sequences, and conjunctures of events associated with the policymaking process of those instruments and goals (Bennet and Checkel 2014: 6).

The process-tracing analysis is operationalized by triangulating two methods of data collection. Triangulating the two methods of data collection—interviewing and document analysis—reduces the risk of construct validity threats and controls for potential biases in this

“explaining-outcome” research.



The primary method of data collection is interviews with an elite EC policymaker, sustainable finance experts, and business sector representatives. Interviewing important stakeholders helps to give detailed insights into interests and interactions that cannot be retrieved from other data sources. The conducted interviews were semi-structured with open-ended questions. Four interviews were conducted via Zoom or Microsoft Teams and one interviewee responded via email. See Figure 2 for a stakeholder map that outlines each interviewee’s involvement and proximity to the policymaking process as well as their stance with regards to their general opinion being ‘for’ or ‘against’ the current design of the sustainable finance agenda.

The procedure for respondent selection was purposive sampling. Respondents were identified based on their type (policymaker, business sector representative, etc.), their position for or against the agenda, and their proximity to the policymaking process. This ensured a broad and diversified response. The EC policymakers were found by looking into current EU DG FISMA sustainable finance employees. The business sector representatives and other sustainable finance experts/civil society actors were found through the public contribution records of the 2020 EU stakeholder consultation. All communication went via LinkedIn and/or email. Following this procedure, I identified thirteen EU policymakers, nine business sector representatives, and three other sustainable finance experts/civil society actors. From this sample, a total of five respondents (one policymaker, two business sector representatives, and two civil society/sustainable finance experts) were willing to engage in this research.

The first interview was conducted with Frédéric Hache, Co-Founder and Executive Director of the Green Finance Observatory. Frédéric Hache was identified based on his response in the 2020 stakeholder consultation where he, as one of few, responded that “no further policy action was needed” regarding sustainable finance. His position is thus against the EU Sustainable Finance Strategy. After having worked in the financial sector for 12 years, Frédéric Hache joined Finance Watch where he managed the policy analysis team and analyzed European prudential regulation of banks and capital markets. Following this, he founded the Green Finance Observatory to focus on researching market-based solutions applied to environmental and social policies (including natural capital, carbon, and biodiversity markets, catastrophe bonds, and sustainable finance) and analyze whether these market mechanisms can deliver on their promises. He additionally lectures in sustainable finance at Sciences Po. His influence in the policymaking process is restricted to engagement in public consultations or (un)official meetings with policymakers. This interview provided the response of an actor with


The second interview was with Paulina Dejmek Hack. Paulina Hack was selected based on her position as EC policymaker and is, therefore, an actor with significant influence in the policymaking process and holds a position very much in favor of the strategy. Currently, she is the Director for General Affairs at the Directorate-General Financial Stability, Financial Services, and Capital Markets Union (DG FISMA). In her work, she is responsible for all the horizontal coordination work of DG FISMA and international sustainable finance. Before that, she was an economic advisor to the President of the European Commission, Jean-Claude Juncker. This elite interview was very insightful because Paulina Dejmek-Hack is a high-level EU policymaker who has been involved with the EU sustainable finance agenda from the very beginning. Due to the privacy preferences of Paulina Dejmek-Hack, the conversation was not recorded. All references and quotes from Paulina Dejmek-Hack in this thesis are drawn from public records but are consistent with the insights she provided in the interview.

The third interview was with Victor van Hoorn, Executive Director at the European Sustainable Investment Forum (Eurosif). Victor van Hoorn was selected to get the perspective of a civil society actor that sits right in the middle between policymakers and the (financial) business sector stakeholders. Eurosif is the leading pan-European Sustainable and Responsible Investment membership association advocating for a sustainable financial system. Its membership includes over 500 organizations across Europe. Victor van Hoorn’s influence is therefore also restricted to engagement in public consultations and (un)official meetings with policymakers. However, the organization's strong sustainable finance expertise and focus do make it has a renowned reputation within Europe among both policymakers and the business sector. Victor van Hoorn presented a mixed opinion on the agenda. The interview gave important insights on the current state of play of the EU sustainable finance landscape and how it evolved. Victor van Hoorn also participated in the 2020 public consultation and indicated to want “more additional policy action”. The interview was conducted in Dutch. All quotations of Victor van Hoorn in this paper are translated to English as accurately as possible.

The fourth interview was with Carolina Vigo, the advisor at BusinessEurope. This is Europe’s largest business sector interest group and one of the most active lobbyists in Europe.4 Carolina Vigo was selected because of her position as advisor responsible for sustainable finance at the interest group. BusinessEurope engaged in the 2020 consultation and indicated to want “incremental additional actions may be needed in targeted areas, but existing actions implemented under the Action Plan are largely sufficient.” This interview provided the

4 See www.integritywatch.eu and ec.europa.eu/transparencyregister/


important perspective of a business sector interest group actor. As demonstrated by the map, BusinessEurope’s influence is the second-highest among all respondents because on top of regular engagement via public consultations and (un)official meetings with policymakers, they are also a member of the EC Platform on Sustainable Finance. The EC selected them to provide additional input in policy developments regarding sustainable finance. Carolina Vigo had a largely favorable attitude regarding the agenda. This interview provided useful insights from the perspective of a business interest group with medium influence in the process and a generally favorable attitude towards the agenda.

The fifth interview was with Zoé van Hamme. Zoé van Hamme currently works as an EU policy advisor at a financial sector interest group in Brussel. Zoé van Hamme was also selected through the 2020 stakeholder response list because the business sector interest group she works for indicated to want “no additional policy action” regarding sustainable finance in Europe. This added a second business sector perspective, but one that is more against the agenda. The influence of this group is limited to engagement via public consultations and (un)official meetings with policymakers. However, the group is also part of a pan-European organization of similar financial sector groups. Therefore, they have two channels of influence as opposed to one. In her work, Zoé van Hamme represents and defends the interest of a financial industry sector interest group (hereafter referred to as the financial sector industry group). Part of the work activities includes closely following sustainable finance legislative developments, engaging in public consultations, and other sector initiatives. This interview provided useful firsthand insights into engagement activities, positions, and concerns regarding the EU Sustainable Finance Strategy. Zoé van Hamme’s participation in the interview was in her name, not that of the industry group she works for. To ensure due diligence, the name of the financial industry group will therefore not be mentioned.

All respondents were duly informed of the purposes of the interviews and their privacy rights. The information sheet provided to the interviewees as well as the questionnaires can be found in Appendix II. Transcripts from all but one interview can be received upon request.


Figure 2: Stakeholder Map

Document analysis

The second method of data collection is document analysis. This method helps to establish that the EU Sustainable Finance Strategy is a policy mix, that incongruence exists between the goals and instruments, provides context around the interview findings, and verifies claims made by interviewees to control for biases.

To analyze the (media) documents, this research adopted a thematic analysis. This is an approach in the “search for concepts-ideas that are more abstract than the actual data in an empirical study” (Yin 2011: 93). And the “collection of concepts may be assembled in some logical fashion that then might represent a theory about the events that have been studied”

(ibid.). Given that this paper relies on already well-established concepts in scholarly literature, a deductive approach was adopted. This means that for all concepts in this paper, pre-defined labels were established which were then manually coded. Please see Appendix III for the coding guide of this document analysis.

Given that the EU Sustainable Finance Strategy is an evolving policy agenda, a timeframe of analysis has been set from 1 January 2016, the year the EC appointed the first High-Level Expert Group on Sustainable Finance (HLEG), until 1 January 2022 which marks

Against For

-5 +5


Victor van Hoorn Frédéric



Paulina Dejmek Hack

Zoé van Hamme

Carolina Vigo

= EU policymakers

= Business Sector Interest Groups

= CSO/EU SusFin experts


the day the full set of rules under the Sustainable Finance Disclosure Regulation (SFDR) instrument were supposed to go into enforcement.5

The documents used for analysis consist of fourteen official EU reports, communique, and press releases that are all publicly available. In addition, three documents were analyzed covering the 2020 public consultation, and the media analysis comprised 11 documents.

5 On 25 November 2021, The European Commission informed the European Parliament and the Council that the application of the Level 2 measures under the SFDR is postponed until 1 January 2023. SFDR Level 2 will introduce regulatory technical standards through which asset managers have to justify their fund categorizations (how green they are) through a series of both environmental and social principal adverse impact disclosures.

See: https://www.esma.europa.eu/sites/default/files/library/com_letter_to_ep_and_council_sfdr_rts-


Chapter III Emerging Incongruence

Despite its relatively short existence, the EU sustainable finance agenda has already undergone an extensive design and change process which has influenced the design of the current EU Sustainable Finance policy mix. Based on Rogge and Reichardt’s (2016) framework for the extended policy mix, this chapter will trace how the EU sustainable finance agenda emerged and how this had an influence on the incongruence between the policy objectives and instruments.

In line with Rogge and Reichardt’s (2016) building blocks of the extended policy mix concept, the EU Sustainable Finance policy mix is made up along the lines of three requirements: the inclusion of a strategic component, the incorporation of associated policy processes, and the consideration of certain characteristics of policy mixes. These requirements are demonstrated in the three building blocks: elements, processes, and characteristics.

2018: EU Action Plan for Financing Sustainable Growth

Before diving into the characteristics of the current mix, it is important to go back to the very beginning of the EU Commission’s ambition to forward sustainable finance in Europe and establish: In what context did the policy mix emerge and develop?

High-Level Expert Group

This ambition predates the EU Green Deal and can be traced back to 2016 when the EC, under the lead of President Jean-Claude Juncker, appointed a High-Level Expert Group (HLEG) to develop a blueprint of reforms along the investment chain to transform the financial system to be in line with the—at the time recently signed—Paris Agreements. The membership of the HLEG was made up of EU policymakers, financial sector representatives, and other sustainable (finance) experts from NGOs and other platforms. They wanted a diversified stakeholder input.

After two years of consultation, the HLEG published a report concluding that sustainable finance was about two urgent imperatives: 1) “to finance sustainable and inclusive growth by funding society’s long-term needs,” and 2) “strengthening financial stability by incorporating environmental, social and governance (ESG) factors into investment decision- making” (HLEG 201: 5). They published a roadmap that outlined eight key recommendations and several cross-cutting recommendations and actions targeting specific sectors of the financial system. Figure 3 provides an overview of all the HLEG’s recommendations.


Notable from the report is that, despite the EU Green Deal not being in existence yet, the HLEG already recognized that the scale of investment necessary to reach the Paris Agreements would be well beyond the capacity of the public sector alone and therefore it would be crucial to increase private finance for sustainable development (HLEG 2018: 12–13).

Further, the HLEG hinted that sustainable finance would be a powerful tool for “achieving its goals of economic prosperity, social inclusion, and environmental regeneration” and that a

“joined-up approach” with a “multi-dimensional roadmap” would be necessary to achieve the transformation (HLEG 2018: 9–10). These are early hints that sustainable finance can serve multiple objectives with multiple policy instruments. The HLEG laid the foundation for what would later become the EU sustainable finance policy mix.

Figure 3: HLEG’s (2018) Final Report Recommendations

Action Plan

Following the HLEG’s recommendation report, on 8 March 2018, the EC (2018a) launched the initial “Action Plan on Financing Sustainable Growth.” The EC stated that this Action Plan was a part of the Capital Markets Union’s (CMU) efforts to connect finance to the specific needs of the European economy to benefit the planet and society (idem: 1).

To achieve those broader objectives, the EC outlined three different goals and ten concrete actions that would be necessary to achieve those goals. The stated goals were to:

Key recommendations Other cross-cutting recommendations Sectoral recommendations

Create common sustainable finance taxonomy;

EU omnibus proposal to clarify investor duties to extend time horizons and bring greater focus on ESG factors;

Upgrade Europe’s disclosure rules to make climate change risks and opportunities fully transparent;

Empower and connect Europe’s citizens with sustainable finance issues;

Develop official European sustainable finance standards;

Establish a ‘Sustainability Infrastructure Europe’ facility;

Reform governance and leadership of companies to build sustainable finance competencies; and

Enlarge role and capabilities of ESAs to promote sustainable finance as part of their mandates.

• Tackle short-termism;

• Empower citizens to engage and connect with sustainable finance issues;

• Establish an EU Observatory on sustainable finance to support evidence- based policy-making;

• Greater transparency on indices and benchmarks;

• Consider sustainability issues as part of accounting standards;

• Accelerate action to finance energy efficiency investments;

• ‘Think Sustainability First’ Principle; and

• Leveraging EU Action to enshrine sustainable finance at global level.

Banking: align lending and financing with EU sustainability objectives;

Insurance companies: underwrite sustainability conditions;

Asset management: Ensure that governance, expertise and stewardship practices take account of sustainability;

Pension funds: Consult beneficiaries on sustainability preferences and build those into investment strategies;

Credit ratings and sustainability ratings:

incorporate ESG factors;

Stock exchanges and financial centres:

provide market infrastructure supporting sustainable asset classes;

Investment consultants: incorporate ESG into advice towards clients; and

Investment banks: incorporate ESG into sell- side research.



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