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Getting Started with the Invest Europe Framework

Understand the Invest Europe ESG framework, its core principles, key data requirements, and how the KEY ESG platform supports consistent and efficient reporting.

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Written by Femke Hummert
Updated over a week ago

What Is the Invest Europe Framework?

The Invest Europe ESG Framework is a voluntary, principles-based framework designed to help private equity, venture capital, and infrastructure investors systematically integrate Environmental, Social, and Governance (ESG) considerations into their investment processes.

It provides a common structure for assessing ESG risks, opportunities, and performance across portfolio companies, while allowing flexibility to reflect different strategies, geographies, and asset classes. The framework aims to promote transparency, comparability, and best practice across the European private capital industry.

Who Is the Invest Europe ESG Framework Aimed At?

The framework is primarily designed for:

  • Private Equity Firms: Including buyout, growth, and mid-market investors.

  • Venture Capital Firms: Supporting ESG integration at early and growth stages.

  • Infrastructure Investors: Addressing asset-level ESG risks and long-term sustainability considerations.

  • Limited Partners (LPs): Providing a consistent basis for ESG reporting and due diligence across portfolios.

Key stats

  • 647 member organisations in 2024

  • Members are based in 57 countries, including 42 European countries in 2024

  • Rough equal split of membership types in 2024:

- Private equity firms

- Venture capital firms

- Limited partners (LPs)

Invest Europe Data Collection Levels Explained

The Invest Europe ESG Framework recognises that portfolio companies vary significantly in size, maturity, and risk profile. To ensure ESG data collection is proportionate and practical, the framework defines three different levels of data collection:

  • Full Portfolio Company (Full PC)

  • Intermediate Portfolio Company (Intermediate PC)

  • Minimum Portfolio Company (Minimum PC)

Data collection level

Description

Who is this suitable for?

What data is included?

Full Portfolio Company (Full PC)

Full PC represents the most comprehensive level of ESG data collection under the Invest Europe framework. It is designed for larger, more mature portfolio companies with greater operational complexity and ESG risk exposure.

Full PC data collection is typically applied to:

Large or mature portfolio companies

Companies with higher ESG risk profiles

Businesses operating in regulated, high-impact, or high-risk sectors

Companies with sufficient internal resources and reporting capability

Full PC reporting usually includes:

Detailed environmental data (e.g. emissions, energy, waste, climate risks)

Comprehensive social metrics (e.g. workforce composition, health & safety, DEI)

Governance indicators (e.g. board structure, policies, controls, cybersecurity)

Policies, processes, and performance trends over time

Intermediate Portfolio Company (Intermediate PC)

Intermediate PC is a balanced level of ESG data collection, providing meaningful ESG insight without the full reporting burden of Full PC.

Intermediate PC is commonly applied to:

Mid-sized portfolio companies

Growing businesses with developing ESG processes

Companies with moderate ESG risk exposure

Assets transitioning toward more mature ESG reporting

Intermediate PC typically includes:

A focused set of environmental and social metrics

Key governance indicators

High-level policies and controls

Selected performance indicators aligned with material risks

Minimum Portfolio Company (Minimum PC)

Minimum PC represents the lightest level of ESG data collection under the Invest Europe framework. It is designed to ensure baseline ESG visibility while minimising reporting burden.

Minimum PC is generally applied to:

Small or early-stage portfolio companies

Venture-stage businesses

Companies with low ESG risk exposure

Assets with limited data availability or reporting capability

Minimum PC reporting focuses on:

Core ESG screening questions

Basic health & safety and workforce indicators

Fundamental governance and compliance checks

Identification of any critical ESG risks or red flags

Reporting Scope and Application

The Invest Europe ESG Framework is applied across the full investment lifecycle, and is an annual based framework supporting ESG integration from pre-investment through ownership and exit.

Key Stages Covered:

  • Pre-Investment: ESG due diligence to identify material risks and opportunities.

  • Ownership: Ongoing ESG monitoring, data collection, and engagement with portfolio companies.

  • Exit: Demonstrating ESG progress, risk management, and value creation outcomes to potential buyers.

Alignment with Other ESG Frameworks

The Invest Europe ESG Framework is designed to be interoperable with other commonly used standards and regulations, including:

  • SFDR (PAIs - Principal Adverse Impact indicators)

  • CSRD & ESRS

  • ESG_VC

  • ESG Data Convergence Initiative (EDCI)

  • ESG Convergence for European Life Science VC

  • Invest Europe GP ESG Due Diligence Questionnaire

  • ESG Due Diligence Questionnaire

  • European Data Cooperative (EDC)

This makes it a practical foundation for firms that need to report across multiple ESG frameworks without duplicating effort.

Implementing Invest Europe ESG Reporting with the KEY ESG Platform

The KEY ESG platform helps firms operationalise the Invest Europe ESG Framework in a structured, scalable way.

Structured ESG Data Capture:

  • Capture ESG data across environmental, social, and governance topics aligned to Invest Europe guidance.

  • Tailor data collection by asset class, sector, and portfolio maturity.

Materiality-Led Reporting:

  • Focus on the ESG topics that matter most to your investments.

  • Maintain flexibility while ensuring consistency across the portfolio.

Portfolio-Level Oversight:

  • Monitor ESG performance and risks across funds and portfolio companies.

  • Identify trends, gaps, and engagement priorities over time.

Audit-Ready and Investor-Grade Outputs:

  • Generate clear ESG summaries and reports for LPs and internal stakeholders.

  • Support alignment with SFDR, EDCI, and other reporting requirements using a single data source.

User-Friendly Experience:

  • Intuitive dashboards and workflows simplify ESG management for investment and operating teams.

  • Reduce reporting burden while improving data quality and comparability.

  • Customisable reporting functionalities

Conclusion

The Invest Europe ESG Framework provides a flexible yet robust foundation for integrating ESG into private capital investment processes. By focusing on material risks and opportunities across the investment lifecycle, it helps firms strengthen governance, manage sustainability risks, and demonstrate responsible ownership.

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