Response of the Platform on Sustainable Finance to the call for feedback on the draft Taxonomy Delegated Acts

03 May 2023

The Platform has made a series of recommendations aimed at improving the usability and applicability of criteria of specific activities; Some criteria are not described with sufficient clarity to allow their standardised application and verification.

Summary of the Platform’s key feedback points

The Platform has analysed the draft Taxonomy Delegated Act and the amendments to the Taxonomy Disclosures Delegated Act through the lenses of usability and consistency.
Our recommendations may be summarised as follows:
• The Platform has made a series of recommendations aimed at improving the usability and applicability of criteria of specific activities:
• Some criteria are not described with sufficient clarity to allow their standardised application and verification.
• Some criteria cannot be applied to the full scope of the activity.
• For some activities, the scope is not clearly defined, or it overlaps, or is broader than recommended. The scope of some activities can be extended without jeopardizing the quality of the criteria, while at the same time increasing the coverage of the Taxonomy.
• Not all criteria that reflect the same concept and are applied in the criteria of several activities are consistent across these activities.
• The Platform proposes to simplify the criteria by avoiding any conditions on criteria but clearly stating whether the criteria are cumulative (“all of the following criteria”) or separate (“any of the following criteria”). If one of a list of separate criteria is the preferred option, regular revision of the criteria should be indicated.
• The Platform urges not to leave at the discretion of a company, economic actor, or the auditor the setting of the criteria or the interpretation of the level of ambition. It will make taxonomy-alignment comparability for these activities impossible and will undermine a fundamental principle of the Taxonomy which is the reliability of the criteria.
• The Platform has made some concrete proposals to reduce the data required to companies without compromising the environmental ambition level.
• The Platform urges the European Commission to allow one activity to be able to be categorised as low-carbon or as transitional depending on which set of criteria it complies with when given two options. The Platform suggests clarifying whether the activity is low-carbon or transitional and adjust the criteria accordingly. “Overperformance” of companies is possible for all transitional activities without the activity changing its label....

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