The European Banking Federation has published a response to the European Commission’s call for evidence on guidance for applying the Do No Significant Harm (DNSH) principle under the 2028-2034 MF, backing simplification and calling for DNSH to be more practical and aligned with existing laws. It argues for reducing duplicative checks, relying more on existing standards and data, and applying proportionality, particularly for financial institutions, SMEs and individuals. The response proposes increased reliance on existing EU and national legislation to evidence compliance, mapping DNSH criteria against current regulation to improve clarity and consistency, and accepting recognised certifications and standards to streamline assessments. It also calls for DNSH evidence requirements that reflect financial institutions’ intermediary role, clearer guidance for activities in third countries including recognition of international standards, improved access to public data and shared platforms, and DNSH criteria presented in clear, quantifiable and structured formats. The EBF adds that a proportionate framework should exempt SMEs and individuals where appropriate given limited access to detailed data.
European Banking Federation 2026-04-01
European Banking Federation urges the European Commission to simplify and apply proportionality in Do No Significant Harm guidance for the 2028-2034 MF
The European Banking Federation has responded to the European Commission’s call for evidence on guidance for applying the Do No Significant Harm principle under the 2028-2034 Multiannual Financial Framework, supporting simplification and closer alignment with existing EU and national laws. It calls for reduced duplicative checks, greater reliance on existing regulation, recognised certifications and public data, clearer and more quantifiable DNSH criteria, and proportionate evidence requirements that reflect financial institutions’ intermediary role and the constraints faced by smaller clients, including in third-country contexts.