ICMA responds to the draft Delegated Act supplementing the EU Taxonomy Regulation

18 December 2020

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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