Brussels, 4 April 2025 – The European Banking Federation (EBF) has submitted its response to the European Commission’s consultation on the Clean Energy Investment Strategy. Key messages:

• Stimulating demand: Raising consumer awareness, simplifying regulatory requirements, and providing guarantees and financial incentives are key to boosting both origination and demand for energy efficiency-related financial products.
• Bankable projects: Aggregators, technical assistance, and capacity‑building are essential to structure the market, standardise projects, and create bankable pipelines that attract large-scale private investment.
• De-risking instruments: Guarantee schemes must de-risk projects across the full lifecycle – especially for SMEs and building renovations – to unlock private capital and accelerate market development.
• Removing fragmentation barriers: Regulatory fragmentation, low awareness, and insufficient standardisation across Member States prevent ESCOs from scaling and operating effectively across the EU.
• Improving EU-level support: InvestEU is a valuable EU-level model but requires simplified access – especially for SMEs – to fully support the scaling of energy‑efficiency investments.

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

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