Brussels, 15 April 2026 – The European Banking Federation (EBF) has submitted its response to two European Commission’s consultations on EU Taxonomy Delegated Acts to update and simplify the technical screening criteria.

While we strongly support the goal of simplifying and harmonizing the technical screening criteria, we are calling on the Commission to ensure more ambitious and structural simplification of how taxonomy alignment is assessed.

Considering that the complexity around technical screening criteria and incoherence with relevant legislation remains high, and the proposal would necessitate substantial efforts when adapting the internal processes to the new criteria, we believe the proposed simplification is insufficient to significantly improve the usability of the whole Taxonomy framework.

The whole Taxonomy-alignment approach should become more pragmatic, the criteria should be clearer, easier to apply, and more directly grounded in existing legislation.

Our key suggestions to improve the taxonomy framework are as follows:

• Exempt individuals and SMEs from DNSH assessment,
• Exempt retail exposures, public entities and EU companies operating in the EU from MSS assessment,
• Avoid strengthening the technical screening criteria where this is not related to changes to sector-specific legislation,
• Align the technical screening criteria with EU legislation to the maximum extent possible to ensure consistency across the EU regulatory framework,
• Make available a list of technical screening criteria mapped against existing legislation,
• Align the technical screening criteria across the whole value chain,
• Streamline evidence by accepting recognised certifications and registrations,
• Include clear guidance on assessing taxonomy-alignment in third countries,
• Improve data availability through public databases,
• Allow greater use of credible estimates in proving taxonomy alignment,
• Ensure consistent application of technical screening criteria across the EU,
• Ensure no further validation or verifications of documents provided by clients,
• Ensure that contracts with binding obligations to meet the technical screening criteria are sufficient to demonstrate the compliance,
• Ensure that activity should remain taxonomy aligned for the entire duration of the loan.

Jānis Priekulis, Senior Policy Adviser – Sustainable Finance, j.priekulis@ebf.eu

Denisa Avermaete, Head of Sustainable Finance, D.Avermaete@ebf.eu