EBF POSITION PAPER

EBF on the EU Platform’s Preliminary Recommendations for Technical Screening Criteria for the EU Taxonomy

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Brussels, 24 September 2021 — Please find below a few key points of the EBF’s position:

• The EBF suggests that the European Commission make the technical screening criteria (TSC) for the remaining environmental objectives more compact and more manageable – driven by the principles of practicality and usability. It is important that any developments avoid overburdensome reporting which would disadvantage certain EU players and sectors.
• It is critical to get the timing right: we would suggest carefully assessing lessons learned from applying the climate change mitigation and climate change adaptation TSC before publishing the TSC for the other four environmental objectives.
• It will be important to provide support to banks and the real economy. Banks will need the EC’s additional support as data is not yet conclusively available for many of the areas/sectors and companies will need guidance on how to present alignment (or eligibility) evidence to banks in connection with financing. This will improve the usability of data overall as banks will have data presented to them in a clearer format.
• A dynamic framework which accommodates transitional activities is needed: a transition taxonomy, rather than a static approach based on best performance, will be the only way to help banks accompany their clients, and the economy as a whole, on their transition path.

For more information:

Denisa Avermaete, Senior Policy Adviser, Sustainable Finance, d.avermaete@ebf.eu

Alexia Femia, Policy Adviser, a.femia@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.