The Dutch Banking Association fully supports the government’s goal to accelerate the sustainability of the (real) economy. The climate and energy transition is a shared responsibility of government, business and consumers (‘the real economy’) and the financial sector. Banks are also taking on that responsibility.

In its response to the consultation of the Ministry of Finance and the Ministry of Economic Affairs and Climate Policy on this subject, the NVB therefore expresses support for accelerating the necessary sustainability. At the same time, it makes clear that a number of other and additional political choices are needed.

No legal obligation of best efforts or enforceable engagement policy

For example, the NVB is against a national legal obligation of best efforts and enforceable involvement policy for the financial sector focused on climate mitigation and the energy transition. This can disrupt the interplay between government, real economy and the financial sector and the banking level playing field. Successful financing opportunities require successful sustainable business cases. Supporting and challenging to making the real economy by consumers and businesses more sustainable is a crucial part of this.

Regulations based on concrete transition paths, standards and reading

The NVB is in favour of stimulating the real economy on the basis of concrete transition paths and through norming and pricing, where it is important that the level playing field is respected. In an effective interplay between government, financial sector and the real economy, this will give direction to sustainability and also accelerate it. For the banks, for example:

• Sectoral transition paths in line with a 1.5-C scenario so that it becomes clear which activities and financial flows banks need to phase out and scale up
• A more comprehensive public funding toolbox for consumers and businesses towards halving emissions by 2030 and climate neutrality by 2050
• A legal basis for the outquiry of emission data, for example in the context of CSRD, so that banks can assist customers even more specifically in their sustainability
• Gradual phases of new stricter emission standards, so that it is clear to consumers, businesses and banks what standards they have to meet in what period of time.

Strengthening through (European) laws and regulations that do not disturb the level playing field

In particular, European laws and regulations can significantly strengthen the role of banks in the climate and energy transition. It must apply to all European banks. Additional (legal) provisions at national level will be less effective because it creates the risk of crossing existing and upcoming legislation, which also disrupts the level playing field. The NVB therefore proposes to give priority to the development in the coming years and, if necessary, to evaluate recently introduced European rules. She would like to talk to the coming period.