The European Banking Federation has submitted a response to two European Commission consultations on EU Taxonomy Delegated Acts, supporting the objective of simplifying and harmonising the technical screening criteria but arguing that the proposed changes are not ambitious enough to materially improve the framework’s usability. It points to continued complexity, inconsistencies with relevant legislation and significant implementation effort for banks adapting internal processes. The federation calls for a more pragmatic approach to assessing taxonomy alignment, with clearer criteria grounded in existing legislation. Its recommendations include exempting individuals and small and medium-sized enterprises from do no significant harm (DNSH) assessments and exempting retail exposures, public entities and EU companies operating in the EU from minimum social safeguards (MSS) assessments; avoiding any strengthening of criteria not linked to sector-specific legislative changes; aligning screening criteria with EU law and mapping them against relevant legislation; aligning criteria across the value chain; accepting recognised certifications and registrations as evidence; providing guidance for third-country assessments; improving data availability via public databases; allowing greater use of credible estimates; ensuring consistent application across the EU; avoiding additional validation of client-provided documents; treating contracts with binding obligations to meet the criteria as sufficient evidence; and requiring that an activity remain taxonomy-aligned for the full duration of the loan.

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