Brussels, 1 April 2026 – The European Banking Federation supports all  simplification efforts and is advocating for making DNSH simpler, more practical, and aligned with existing laws by reducing duplication, leveraging existing standards and data, and applying proportionality, especially for financial institutions, SMEs, and individuals.

A more practical, proportionate approach would:

• Increase reliance  on existing EU and national legislation to demonstrate compliance, avoiding duplicative checks
• Map DNSH criteria against current regulations to improve clarity and consistency
• Accept recognised certifications and standards to streamline assessments
• Reflect the intermediary role of financial institutions with realistic evidence requirements
• Provide clear guidance for activities in third countries, including recognition of international standards
• Improve access to public data and shared platforms to reduce costs and inconsistencies
• Make DNSH criteria more usable through clear, quantifiable, and structured formats

Importantly, a proportionate framework should also exempt SMEs and individuals where appropriate, acknowledging their limited access to detailed data.

Simplification, consistency, and usability will be critical to ensure DNSH works effectively in practice — supporting both sustainability goals and transition financing.

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

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