EBF CONSULTATION RESPONSE
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Call for Evidence: Review of the EU Taxonomy Environmental and Climate Delegate Acts

Brussels, 5 December 2025 – We strongly support the goal of simplifying the technical screening criteria, enhancing clarity and coherence, and reducing unnecessary complexity while maintaining robust environmental standards and the overall integrity of the EU Taxonomy framework.

We support a comprehensive review of all assessment criteria, especially the DNSH rules, aiming for simplification, proportionality, practical applicability and consistency with EU law. The documentation of the taxonomy alignment should also be simplified.

Key proposals

1. 1. Exempt retail exposures from DNSH and MS assessment
   2. Adapt MS and DNSH for EU-based entities – the extent to which statutory requirements could be envisaged for compliance with the DNSH/MS should be reviewed.
   3. Consider equivalence approaches for non-EU jurisdictions
   4. Allow financial institutions to rely on the alignment data provided by the client – the burden of proof and liability should lie with the client, not with the financial institution
   5. Streamline evidence by accepting recognised certifications
   6. Further improve readability and usability of the EU Taxonomy
   7. Align the criteria across value chain
   8. Align technical alignment criteria for commercial real estate with those of residential real estate
   9. Incentivize renovation by accepting alignment with renovation criteria for acquisition of buildings
   10. Allow grandfathering of EU Taxonomy alignment – taxonomy-aligned exposures should remain aligned for the entire duration of the financial instrument for all Use of Proceeds exposures.
   11. Improve data availability through public databases

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For more information:

Denisa Avermaete, Senior Policy Adviser, Sustainable Finance, d.avermaete@ebf.eu
Jānis Priekulis, Policy Adviser, Sustainable Finance, j.priekulis@ebf.eu
Emanuela Manenti, Intern, Sustainable Finance, e.manenti@ebf.eu

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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together 32 national banking associations in Europe that together represent a significant majority of all banking assets in Europe, with 3,500 banks – large and small, wholesale and retail, local and international – while employing approximately two million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that reliably handle more than 400 million payment transactions per day. Launched in 1960, the EBF is committed to a single market for financial services in the European Union and to supporting policies that foster economic growth.