European green bonds

The Association of German Banks very much welcomes the opportunity to comment on the draft EU Green Bond Standard (EuGBS). In principle, we very much appriciate COM’s proposal. From our point of view, several amendments to the EuGBS are necessary in order to make EuGBS a widely used premium standard. At this point, we only highlight some key aspects and outline our further comments in an accompanying document. 1.

The 23 members of the Corporate Forum on Sustainable Finance (the Forum), emanate from 8 countries and 5 business sectors. With over EUR 90bn outstanding, the Forum accounts for nearly two-thirds of European sustainable bond issues. The Forum welcomes the consultation on the EU Green Bond Standard (the EU GBS).

SNCF welcomes the introduction of a European green bond standard. SNCF is the oldest issuer of green bonds in the European and global rail market and one of the largest in volume. The group has €7.6 billion of outstanding green bond debt, i.e. 11% of the SNCF group's total gross bond debt (as at 30 June 2021).

We thank for the opportunity to comment on the draft Regulation on European green bonds. We support the initiative and applaud the leadership of the European Commission, however we have some concerns with the formulation of the draft Regulation. We recommend that the following be considered (detailed response attached): 1.

Terna welcomes the EC consultation on the proposal for a EU Green Bond Standard Regulation and related annexes. In this respect, Terna would like to present to the Commission some considerations that should be taken into account in the next steps for the publication of this Regulation. In particular, we would like to comment the Item 4.2 of Annex I and Item 4 of Annex III to the draft Regulation.

The Caisse des Depots Group is a National Promotional Institution (NPI), and main financing actor of sustainability in France, as well as a long-term institutional investor with a long-standing commitment to responsible investment. As such, Caisse des Depots Group issues sustainable (ESG) obligations since 2017.

ABI provides hereinafter first comments on the EU Green Bond Standard Proposal Regulation (EUGBS), adopted by the European Commission in July 2021, which introduces a common framework of rules governing green bond issuances in accordance with the provisions of Regulation (EU) 2019/2088 on Taxonomy.

ENGIE welcomes the opportunity to comment on the proposed EU Green Bond Standard (EuGB). We believe this voluntary harmonised standard may boost the uptake of green bonds in the EU and confirm EU leadership on this matter if the standard is clear and well-designed. 1.

The IDW supports the Proposal for a Regulation of the European Parliament and of the Council on European green bonds. Our attached letter discusses the following: Our Support: The IDW welcomes the Proposal as an important part of the European Commission’s broader agenda on sustainable finance, which we fully support.

The sustainable transformation of society is an important and necessary agenda. Consumers, businesses and the financial sector need to contribute — no one can do this alone. The financial sector is part of all parts of the economy and is therefore an important catalyst for the development of a sustainable Danish economy.

Filed in Danish · English published by the European Commission

ESBG applauds the EU's efforts to develop a binding and consistent green bond standard that is linked to the EU Taxonomy. Below you may find some concerns with the current proposal: • The number of organizational requirements in the proposal (fifty provisions deal with the legal framework of external reviewers and other supervisory powers while only thirteen deal with the green bond itself ) exceed the purpose of…

On behalf of the European Federation of Energy Traders (EFET), we are providing this feedback to the Commission’s draft proposal for a Regulation on European green bonds. The European Federation of Energy Traders promotes and facilitates European energy trading in open, transparent and liquid wholesale markets, unhindered by national borders or other undue obstacles.

The German Property Federation ZIA and the entire real estate industry is aware of its responsibility for climate protection. After all, the building sector is responsible for a large part of CO2 emissions, accounting for almost 40% of the total emission. We therefore feel committed to climate protection and support constructive ideas that lead to greater sustainability.

The German Banking Industry Committee very much welcomes the opportunity to comment on the draft EU Green Bond Standard (EuGBS). Due to the length limitations in the online feedback, we will only highlight some key aspects at this point. Our further comments are outlined in the accompanying document.

Summary of the EAPB position (the full position paper is attached) The EAPB welcomes that the Commission has proposed a voluntary EuGB label rather than a binding one. However, the draft regulation falls short in several crucial respects that, if not addressed, would cause significant problems for both investors and issuers (bond-by-bond issuers as well as issuers who apply a portfolio approach, where a pool of…

GDV welcomes the proposal for an EU Green Bond Standard (EU GBS). Insurers as Europe’s largest institutional investors invest extensively in bonds and therefore have a great interest in measures to stimulate the development of the green bond market as a key means of financing the sustainability transition.

Filed in German · English published by the European Commission

The insurance industry welcomes the EC’s proposal for an EU Green Bond Standard (EUGBS) as a framework to facilitate capital flows to green and transition investments, in line with the Green Deal objectives. As Europe’s largest institutional investor, the sector supports measures to stimulate the development of the green bond market.

Green bonds play an increasingly important role in financing assets needed for the low-carbon transition. Delivering on the European Green Deal requires significant massive investment across all sectors and industries, including transport, to accelerate the transition towards a climate-neutral economy and reach the EU’s environmental sustainability objectives – enshrined in EU law and aligned with the Paris…

OeGV welcomes the opportunity to comment on this proposal for a regulation on European green bonds. General remarks As a general remark we want to indicate that the translations should be carried out more carefully as we recognised a critical translation in the German Version. “Pre-issuance and post-issuance reviews” were translated into “Bewertung vor und nach Emission” which is not correct in our view.

Our key concern with green bonds regards the risk of greenwashing, especially now that financial markets show strong interest in expanding their portfolio with green assets. We welcome the European Commission’s (EC) proposal for an EU Green Bond Standard (EU GBS) that introduces requirements aiming at reducing uncertainties for issuers and investors and bringing credibility to the green bond market.

GB STANDARD PROPOSAL – FEEDBACK ANIA ANIA welcomes the proposal for a European Green Bond standard as both the issuers and the investors would benefit from an improved transparency and a harmonization of the rules for the external reviewers.

Deutsches Aktieninstitut welcomes the proposed voluntary nature for the Regulation on European green bonds (EU GBS) and the intention to ensure its co-existence with existing green bond standards. Furthermore, we support the alignment of the EU GBS with the EU Taxonomy. This is a distinctive feature of the planned EU GBS and a major difference from the previous market standards for green bonds.

We welcome the opportunity to comment on the EU Green Bond Standard (EuGBs). Covered bonds are mostly backed by mortgages on real estate and are essential to put the EU’s building stock on a net-zero emissions pathway. It is important to ensure that the EU Taxonomy works in practice and can be applied to EU covered bond markets, especially considering the long-term nature of mortgages.

The proposal for a Regulation presented by the European Commission lays the foundations for a common framework of rules governing the bonds that follow environmental sustainability objectives in accordance with the provisions of Regulation (EU) 2019/2088 on taxonomy resolving, as pointed out by Anasf in the response to the Commission consultation last year, some of the problems that have negatively affected the EU…

Snam welcomes the opportunity to provide feedback to the Roadmap of the public consultation “Ecofriendly investment – EU standard for ‘green bonds” and would like to provide the following contributions. The adoption of an EU Green Bond Standard has the potential to further develop the market of Green Bonds as it provides more clarity for investors and issuers.

We agree with the EC that green bonds play an increasingly important role in asset finance and we expect that this trend will continue and increase in importance for fixed income investors. Recognising this increasing importance and the role data will play, firms such as IHS Markit are currently engaged in research and development activities around what bond level Green/ESG content could look like.

The Association of German Banks very welcomes the opportunity to comment on the European Commission’s Inception impact assessment on EU Green Bond Standards (EU GBS). Green bonds may prove instrumental in mobilizing the bond market for climate change solutions. The Green Bond market has considerably raised its volumes and is expected to grow further.

With welcome the fact that Europe is taking the lead towards a greener or more inclusive economy. Green bonds are a strong mechanism to steer large parts of budgets (of companies and governments) to green projects. We have four comments on the proposal. 1. The EU GBS wants to be an alternative for the standards that are already out there.

Malta welcomes the Commission’s initiative for a legislative proposal for an EU-Green Bond Standard. Although the issuance of green bonds is a partial solution to financing the mitigation and adaptation of our world’s environmental challenges, many smaller countries might find difficulties in tapping into such a growing market. Malta can be considered as one such example.

- As public transport is inherently a clean, low carbon form of transport it is naturally a prime candidate for Green Bond investment. - Green Bond proceeds should be used for a wide variety of environmental projects in the public transport sector to help advance local level priorities.

• Les autorités françaises soutiennent pleinement l'initiative de la Commission européenne visant à créer un standard européen d'obligations vertes (EU Green Bond Standard) – l’un des piliers du Plan d’action sur la finance durable et du Pacte Vert.

Plastics Recyclers Europe (PRE), the Brussels-based leading association representing the plastic recycling industry, welcomes the proposal to constitute an EU Green Bond Standard as a key element to address and deliver the goal of the Green Deal, the targets of the Circular Economy Action Plan and the objectives of the Strategy for Plastics in the Circular Economy.

The Société du Grand Paris welcomes the European Commission’s desire to implement a European standard on green bonds in the context of the Green Pact. However, if a European standard appears to be essential to achieving the ambitions of the Green Pact, it must be ensured that these measures do not act as a brake on their development.

Filed in French · English published by the European Commission

1. The economy of many European countries is based on the strength of a multitude of small and medium-sized enterprises (SMEs). These have greater difficulty in accessing the capital market and in issuing bonds, given their limited size.