On 18 February, we attended the presentation of the second edition of the report Challenges of Sustainable Investment: Dark Green (2nd edition), a piece of work driven by the International Chair in Sustainable Finance UPF-BSM, promoted by Triodos Bank, which analyses the evolution of the market and the structural challenges facing sustainable investment in Spain and Europe.
The gathering brought together representatives from the academic, regulatory, institutional and financial spheres to debate the current state of the sector, marked by growing regulatory demands, more intense public scrutiny and the need to reinforce the credibility of the market.
Marcos Eguiguren, Associate Provost and Secretary General of UPF-BSM and Director of the Chair, highlighted the importance of generating rigorous knowledge in a context where sustainability has moved from being a trend to becoming a structural axis of the financial system.
Susana Cabada, Director of Personal Banking at Triodos Bank Spain and member of the Academic Council of the Chair, underlined the role of purpose-driven banking in channelling savings towards projects with genuine positive impact, as well as the need to preserve the transformative ambition of sustainable investment.
Report results and conclusions: between consolidation and redefinition
The report’s results were presented by its co-authors: Oscar Elvira, Senior Lecturer at UPF-BSM, and Patricia Gabeiras, Founding Partner of Gabeiras & Asociados and President of Spainsif.
The report identifies a moment of transition for sustainable investment, characterised by:
- Greater regulatory complexity, arising from the deployment of European regulatory frameworks in sustainable finance.
- Reputational and greenwashing risk, requiring greater transparency, traceability and coherence in product classification.
- The need for clarity in ‘dark green’ categories, especially in relation to the most ambitious products in terms of impact.
- Strategic review by asset managers, who are adjusting their policies, methodologies and communications in a more demanding environment.
- Growing demand for reliable and comparable data, key for investment decision-making and supervision.
The authors insisted that the market is not retreating, but maturing. The current adjustment phase responds to the need to align expectations, regulation and real practice, reinforcing the credibility of the ecosystem.
In terms of the quantitative analysis, the report highlights that as of June 2025, total assets invested in sustainable financial products in Spain amounted to €159.504 billion, representing 38% of total assets under management in funds. However, only 0.6% of that total corresponds to funds classified as Article 9 (‘dark green’) — that is, the products with the greatest environmental and social impact ambition. This last group totals just €2.582 billion, evidencing the scant representation of the most demanding sustainability funds in the Spanish market.
Roundtable: regulation, market and public policy in dialogue
In the roundtable, moderated by Patricia Gabeiras, President of Spainsif, the following participated:
- Pablo Esteban, Deputy Director General of Spainsif
- Claudia Antuña, Partner at AFI
- Begoña López, Deputy Director of the Department of Strategy, Innovation and Sustainable Finance at the CNMV
- Antonio Ortiz, Deputy Sub-Director of Sustainable and Digital Finance
One of the cross-cutting messages was that sustainability is no longer a differentiating attribute, but a structural requirement. However, its correct implementation demands technical rigour, regulatory coherence and institutional commitment.
The supervisory role in preventing greenwashing was also addressed, as was the need for greater coordination between public policy and the financial sector — highlighting the work being done through the Sustainable Finance Council and its various working groups, which is progressively providing clarity and tools to the different actors in that alignment.
Finally, the need to maintain climate ambition was identified as a contextual, as well as regulatory and market, challenge.
A turning point for sustainable investment
The presentation of the report highlighted that the sustainable investment market is at a turning point: after years of accelerated growth, it now faces a phase of consolidation, refinement and greater rigour.
In this context of growing regulatory sophistication and debate around SFDR Article 8 and 9 categories, it is worth recalling that impact investment occupies its own space that does not automatically fit within these classifications. Its logic starts from the explicit intentionality of generating measurable social or environmental impact alongside financial return, which implies specific metrics, structures and time horizons.
It is precisely because of this distinctiveness that it is especially positive that the proposed revision of SFDR 2.0 has explicitly incorporated a reference to impact investment within the three new labels proposed (sustainable, transition and ‘ESG Collection’). We welcome this advance and trust that, in the process towards the final text, this reference will be strengthened, as it will bring greater clarity to the market and make it easier for institutional and retail investors to identify and choose with greater precision those investments most aligned with the generation of real impact.
In this regard, SpainNAB is this year working on a market sizing study for impact investment using 2025 data, with the objective of rigorously quantifying its real weight, identifying trends and providing clarity at a moment when measuring well is key to deciding better.
Finally, we are grateful for this work driven by Triodos Bank through the International Chair in Sustainable Finance UPF-BSM, which reaffirms the commitment to independent analysis and dialogue between academia, the financial sector and regulators, contributing to building a more transparent, ambitious market aligned with ecological and social transition objectives.
