The EBF response to the TEG report on EU Taxonomy highlights some elements that could further contribute to steering the taxonomy more optimally towards financing of the gradual shift of the economy to a net zero carbon emitting model by 2050. The qualitative criteria for adaptation should not apply equally to all sectors, as the activities are very much context specific. Further refinement in some areas is necessary in order to encompass the reality of companies’ shift towards increased sustainability. Our main comments relate to the usability of the taxonomy and its implementation feasibility in IT systems and processes. It is important to ensure that the access to finance is not restricted. Especially for SMEs, we have to avoid too burdensome requirements to access sustainable finance. A set of measures could therefore be developed to facilitate the implementation of the taxonomy by financial and non-financial actors.
Although a direct application of the Taxonomy to loans and other banking activities is not currently envisaged by the EU legislation, the EBF and the UNEP FI are launching a project to analyze the potential of the application of the EU taxonomy to bank’s portfolios, identify any shortcoming or need for adaptations in order to make the taxonomy applicable to banking activities for banks that wish to apply the EU taxonomy on a voluntary basis. Upon agreement of participating institutions and the validation of the final scope, the project will aim to develop and promote high-level voluntary guidelines that will facilitate the identification of sustainable activities in banks’ portfolios based on the EU taxonomy, including use cases. It is important to create European incentive policies for both enterprises and banks involved in the transition towards a more sustainable economy. The joint EBF/UNEP FI project to assess the possible usability of the taxonomy beyond its original scope, albeit on a voluntary basis is not only expected to contribute to the debate on the usability of the taxonomy and its future adaptation, but also contribute to facilitation of the application of targeted incentives and further positive effects.
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The EBF is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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