ICMA believes that while Substantial Contribution and DNSH are recognised as fundamental concepts of the Taxonomy, the Delegated Acts or associated commentary could go further to acknowledge that implementation will take time, even for advanced actors, and that some criteria remain undefined.
Further dialogue with the market on usability
is desirable to make this a success. The same is true for work needed
to establish internationally comparable criteria – something the
International Platform could contribute to. Finally, more guidance on
the application of the taxonomy, e.g. how to report investments outside
the EU referenced by an EU Green Bond, would be helpful.
Response
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