Platform on Sustainable Finance response to the Commission’s consultation on the Environmental and Climate Delegated Acts

The Platform on Sustainable Finance, an advisory body to the European Commission, has been consulted by the European Commission on the draft revised Climate and Environmental Delegated Acts under the Taxonomy Regulation.

Following the publication of the revised Climate Delegated Act and Environmental Delegated Act, the Platform completed a review of the texts within five weeks and submitted 280 recommendations to the Commission. Two annexes accompany the main briefing, one for each Delegated Act, setting out the specific recommendations for both substantial contribution and “do no significant harm” criteria.

During the previous mandate, the Platform had already provided detailed recommendations regarding the review of the Climate Delegated Act, many of which have been incorporated in the revised texts. Building on this work, the Platform focused its latest review on the specific areas and issues identified by the Commission, with particular attention to

• enhancing usability and clarity across activities, including ensuring that criteria clearly specify valid means of objective verification
• strengthening policy coherence and consistency with the Taxonomy Regulation, related EU legislation, and market practices
• and maintaining an appropriate level of ambition of the criteria, ensuring their compatibility with the headline ambition levels for substantial contribution established by previous platforms

The majority of the recommendations relate to the Climate Delegated Act, particularly in the sectors of transport, manufacturing, construction and real estate, energy, and forestry.

In addition, the Platform has made two broader recommendations aimed at facilitating the practical application of the taxonomy criteria

1. upgrade the taxonomy compass by linking each criterion to relevant sectoral legislation, and databases, while also incorporating guidance to support implementation of the criteria
2. conduct a comprehensive review of all taxonomy‑related FAQs to ensure alignment with the updated Delegated Acts

Finally, the Platform identified five cross‑cutting issues requiring further reflection in the medium term to support effective implementation of the taxonomy. These include, for example, the differentiation of criteria for financing and operational reporting, the alignment between the taxonomy criteria and the EU emission trading system (ETS) data, as well as the integration of data regarding critical raw materials (CRMs) across the taxonomy.