EBF CONSULTATION RESPONSE
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Draft Report on Taxonomy Extension Options linked to Environmental Objectives: EBF response

BRUSSELS, 14 September 2021 – Please find below a few key points of the EBF response to the consultation:

• The EBF supports the extension of the EU Taxonomy ‘beyond green’ to include significantly harmful activities, therefore creating a ‘permanent significantly harmful’ red category.
• Activities with the potential to improve environmental performance must be considered and should not fall under the category of ‘always harmful’ activities. This intermediate category should encompass all those activities which are not classified as ‘green’ (those activities aligned with the Taxonomy and DNSH criteria) or “red” (those activities which cannot solve DNSH issues).
• The development of a real transition framework is critical as clear guidance on the consistent trajectories of activities is needed. It is fundamental that the extended taxonomy support the transition of entire sectors. Otherwise, there would be the concrete risk of significantly accelerating stranded assets for banks – this would significantly weaken EU banks and their ability to finance the transition of the EU economy.
• Defining an official transition path against which a company’s transition can be assessed should be defined at sector level and by geography by a recognized (public) authority and be aligned with each country’s Nationally Determined Contribution and national climate laws.
• The EU should be cautious and closely evaluate the impact of a ‘red’ taxonomy on the competitiveness of European businesses vis-à-vis the jurisdictions without a similar Taxonomy in force.

For more information:

Denisa Avermaete, Senior Policy Adviser, Sustainable Finance, d.avermaete@ebf.eu
Eleni Choidas, Policy Adviser, Sustainable Finance, e.choidas@ebf.eu
Alexia Femia, Financing Growth, 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.