Guidance on the application of the ‘do no significant harm’ principle under the 2028-2034 MFF

The European Anglers Alliance (EAA) is a European NGO for national angling organisations. Our members have in total some 2 million paying angling members. We welcome the Commission's efforts to "develop a single and simple DNSH guidance.." We just want to warn against phrasing, which could undermine existing environmental legislation.

Legnica, 1 April 2026 ZPPM/17S/IV/2026 European Commission Secretariat-General of the European Commission Rue de la Loi 200/Wetstraat 200 B – 1049 Brussels Brussels/Brussels Belgium/Belgium Reform and Investment Task Force (SG REFORM) European Commission 1049 Brussels/Brussel Belgium Position of the Employers’ Union Polska Miedź on the Commission proposal for a Regulation of the European Parliament and of the…

Filed in Polish · English published by the European Commission

The Austrian Chamber of Agriculture welcomes the objective of establishing uniform guidance for the application of the DNSH principle within the EU budget. Harmonisation can help simplify the currently differing requirements. However, it is crucial that the new guidance does not lead to increased complexity. The criteria and control mechanisms must be designed as simple as possible.

The Do No Significant Harm principle, as an innovation introduced in the 2021-2027 programming period, if applied efficiently, could contribute to strengthening the environmental credibility of EU spending and ensuring that investments are aligned with long-term sustainability goals.

Position paper of the Polish Electricity Association (PKEE) submitted in response to the consultation on the guidance for applying the do no significant harm (DNSH) principle under the 20282034 Multiannual Financial Framework. The document presents key recommendations aimed at simplifying, harmonising and ensuring a proportionate application of DNSH requirements.

The members of the European Association of Long-Term Investors have convened to analyse the Commissions proposed DNSH framework for the next MFF and to formulate constructive feedback grounded in their extensive experience as implementing partners. These discussions highlighted that the new guidance should build directly on the existing InvestEU Sustainability Proofing rather than establish a completely new system.

These views are grounded in our experience providing technical assistance to Italian ERDF Managing Authorities/ Environmental Authorities and acting as Advisory Partner of the IE GreenGov (GREEN finance and Do No Significant Harm principle implementation for a better regional GOVernance).

We appreciate and support the development of unified and simplified DNSH guidelines, and we welcome the planned involvement of Member States in their preparation, which we see as a key precondition for the effective and consistent application of the DNSH principle.

Supply chain Italy, the association that supports and enhances the agri-food supply chain, 100 % of which is Italian, welcomes the European Commission’s initiative to gather opinions on the application of the ‘do no significant harm’ principle under the 2028-2034 multiannual financial framework (MFF). Please refer to the detailed position paper attached.

Filed in Italian · English published by the European Commission

Coldiretti, the largest farmers’ representative organisation in Italy and Europe, with its 1.6 million members, welcomes the European Commission’s initiative to gather views on the application of the ‘do no significant harm’ principle under the 2028-2034 multiannual financial framework (MFF). See detailed position paper attached.

Filed in Italian · English published by the European Commission

The Irish Farmers Association rejects the planned introduction of the Do No Significant Harm (DNSH) principle for agricultural interventions. The agricultural sector, already governed by the CAP Common Agricultural Policy should be totally excluded from the application of the DNSH. Unlike other sectors, agriculture is deeply intertwined with natural resources and ecosystems.

We welcome the new approach to the DNSH principle and propose several solutions to improve its application: 1. Supplement the guidance with sector-specific annexes and an exclusion list. o Sectoral annexes should, as far as possible, take into account the Taxonomy Compass along with technical guidelines for the period 20212027 and Annex D to the Taxonomy.

Snam, European leader in energy infrastructure, welcomes the initiative to produce technical guidance on applying the do no significant harm (DNSH) principle in the next Multiannual Financial Framework 28-34 (MFF). As a key actor in ongoing energy integration, Snam has a direct interest in ensuring that EU funding frameworks are both environmentally robust and operationally workable.

FEAD, the European Waste Management Association, appreciates the opportunity to comment on the application of the do no significant harm (DNSH) principle in the next multiannual financial framework (MFF). FEAD welcomes that the call for evidence clarifies that the DNSH principle under the Taxonomy and the next MFF have different legal basis, objectives, scope and design features.

The Cool Heating Coalition (CHC) welcomes the European Commissions call for evidence regarding the guidance on the application of the 'do no significant harm' (DNSH) principle under the 2028-2034 Multiannual Financial Framework (MFF). CHC is dedicated to achieving renewable, sustainable, and affordable heating and cooling for all by 2040.

FEDENE brings together six professional associations that work to improve energy efficiency and building services, decarbonize heat and cold production using renewable and waste heat, in cities, housing, the tertiary sector, and industry. Its 1,500 local companies, covering the entire value chain and spreading across the country, employ 50,000 people in France.

While we agree with the principle of consistency with the EU Taxonomy (Art. 5), we warn that the DNSH rule in its current form could be difficult to interpret and apply, hence counterproductive. We recommend that the DNSH rule and the related Technical Screening Criteria should be simplified to increase their usability, while also avoiding inconsistent duplicates with the EU Taxonomy or unnecessary reporting burdens…

The forthcoming technical guidance under Article 5 of the Performance Regulation is an important occasion to clarify the interpretation of the DNSH principle for circular economy as well as some concepts left undefined in the Taxonomy Regulation. Please find attached FNADE's contribution to this work.

The European State Forest Association (EUSTAFOR) represents state forest companies, enterprises and agencies that have sustainable forest management (SFM) and sustainable wood production as major concerns. As the Commission develops guidance under Article 5 of the proposed Performance Regulation, it is critical that the "Do No Significant Harm" (DNSH) principle is applied in a way that is clear, harmonized, and…

Invitalia has developed extensive expertise in the area of DNSH through its direct management of aid measures and incentive schemes for businesses, through its support to program-administering authorities in defining and implementing the relevant compliance mechanisms, and, finally, through its technical and operational.

The Health and Environment Alliance (HEAL), the leading not-for-profit organisation addressing how the environment affects health in the European Union and beyond, welcomes the opportunity to provide input into this call for evidence on the upcoming development of a do no significant harm (DNSH) guidance for the 2028-2034 Multiannual financial framework (MFF).

BirdLife Europe welcomes the application of the DNSH principle to the Multiannual Financial Framework. Effective DNSH implementation requires that EU spending contributes to climate and nature objectives, with robust, science-based criteria applied to all six objectives. All DNSH criteria must be met before EU funds are disbursed.

This contribution is submitted by the Belgian federal administration as DNSH SPOC person for the DNSH guidance for the next MFF. It reflects technical and operational considerations based on shared implementation experience across several administrations (Federal, French community, Wallonia Region and Brussels Region) but does not constitute a formal Belgian position or decision.

The Committee considers it important to point out that the principle of proportionality should be explicitly laid down in the application of the DNSH principle, making it clear that the related requirements are calibrated according to the size, complexity and impact of the intervention to be carried out.

Filed in Italian · English published by the European Commission

Legacoop is the first and largest association representing Italian cooperatives. It brings together more than 10.000 cooperatives (both SMEs and large cooperative enterprises) with more than 7 million members, producing more than EUR 86 billion and operating in various sectors including facility management, catering, socio-sanitary, waste collection and disposal, design, execution and maintenance of public works…

Filed in Italian · English published by the European Commission

The purpose of the DNSH principle is to ensure that the investments financed do not cause significant harm to the six environmental objectives defined in Article 9 of Regulation (EU) 2020/852. There are currently no ‘amount thresholds’ below which the DNSH does not apply; evaluation is mandatory for aid and investments of any size, but the complexity of the documentation varies depending on the type of intervention.

Filed in Italian · English published by the European Commission

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants currently operating in Europe. Its mission is to promote technologies that safely treat non-recyclable waste while recovering valuable energy and materials, thereby contributing to Europes climate objectives, resource efficiency, and energy resilience.

The DNSH (Do No Significant Harm) principle in its current form appears to be a redundancy solution which, in practice, does not add real value to the process of project preparation and implementation. Its main effect is to impose additional documentation obligations on beneficiaries, without proportionate impact on actual environmental protection.

Filed in Polish · English published by the European Commission

Leaseurope, the European Federation of Leasing Company Associations, welcomes in principle the European Commission's efforts to harmonise the different approaches to DNSH assessment, but we note it is vital that the DNSH criteria being used do not risk creating unnecessary or disproportionate barriers to the take-up of less-polluting assets.

The European Association of Guarantee Institutions (AECM) and its members welcome the opportunity to contribute to the European Commissions call for evidence on the application of the do no significant harm (DNSH) principle under the 20282034 Multiannual Financial Framework (MFF).

Euromines would like to use this opportunity to address key challenges if the "Do No Significant Harm" (DNSH) principle is streamlined across the 2028-2034 Multiannual Financial Framework, in particular in terms of applicability and scope and the resulting impact on investment uptake.

The Ministry of European Investments and Funds in Romania (MEIP) welcomes the opportunity to contribute to the consultation process on revising the DNSH framework for the 20282034. We view this initiative as essential for ensuring strong coherence between environmental objectives, the EU strategic priorities, and the financing provided through the EU budget.

The agricultural sector, by its very nature, is deeply interlinked with the environment and the responsible use of natural resources, since it must be recognised that agricultural undertakings have always been involved in practices aimed at preserving soil, water and biodiversity, while at the same time having to ensure the economic sustainability of production.

Filed in Italian · English published by the European Commission

CEWEP supports a simplified, proportionate and coherent application of the DNSH principle across EU funding instruments. At the same time, experience with current implementation shows that insufficiently differentiated interpretations risk creating unintended barriers to investments necessary to achieve EU environmental, energy and climate objectives.

Ecologistas en Acción welcomes the application of the Do No Significant Harm (DNSH) principle to the Multiannual Financial Framework, building on experience from the Recovery and Resilience Facility. Effective DNSH implementation requires that EU spending contributes to climate and nature objectives, with robust, science-based criteria applied to all six objectives.

Confindustria welcomes the European Commission's initiative to develop guidance on the application of the "Do No Significant Harm" (DNSH) principle under the 2028-2034 Multiannual Financial Framework. Building on practical experience with the implementation of DNSH across EU funding instruments, the attached contribution highlights key challenges encountered by industry, in particular in terms of complexity…

Due to the operational specificities of the Italian forestry sector, the attached document highlights some structural issues in the strict application of the DNSH principle, which excludes investments in combustion machinery and equipment, as well as activities and assets related to fossil fuels (including downstream use).

Filed in Italian · English published by the European Commission

The German Farmers’ Association clearly rejects the planned introduction of the DNSH principle (Do No Significant Harm) for environmental and climate concerns in agriculture. The DNSH principle does not fit the current challenges of agriculture and forestry either in time or systematically. Agriculture already makes a significant contribution to the environment, climate and biodiversity objectives.

Filed in German · English published by the European Commission

We thank the Commission for this opportunity. Our contribution has been prepared by the national focal point. It takes into account the feedback received from IT public administrations and stakeholders and is based on the extensive experience gained in applying the DNSH principle so far, notably in the Italian NRRP.

CEPF urges the Commission to carefully assess the implications of extending the do no significant harm (DNSH) principle to the 2028-2034 multiannual financial framework (MFF) before proceeding. Our concerns are fundamental, not technical, and we trust the Commission will give them the weight they deserve.

Comments of the Croatian ERDF, CF & JTF MA We welcome the initiative of the European Commission to harmonize the approach to DNSH for the next financial perspective between different funds and fully support initiatives that have the goal of strengthening sustainable development policies and the green and environmental protection agenda.

In its joint contribution, the Nouvelle-Aquitaine Region recalls its role as managing authority for European cohesion policy, as well as its initiatives such as the Néo Terra strategic roadmap, eco-social conditionalities and the Green Budget. New Aquitaine supports the alignment of the DNSH principle across the EU budget and the development of harmonised twelfths to implement it.

Filed in French · English published by the European Commission

The European Commission’s initiative to simplify and harmonise the application of the Do No Significant Harm (DNSH) principle is appropriate as it addresses the identified problems of inconsistency in interpretation and excessive administrative burden.

Filed in Polish · English published by the European Commission

The European DNSH proposal, to which Italy will have to contribute, assumes that there is currently too much heterogeneity in the application of the DNSH principle between different instruments; the aim is therefore to increase consistency of application and reduce complexity, leading to a single guidance document.

Filed in Italian · English published by the European Commission

As Association of Plastic Industries of Greece (SVPE), we agree with the simplification of the way the ‘do no significant harm’ (DNSH) principle is applied in the various EU funding programmes, as we consider it fairer to replace the specific and piecemeal requirements for each Fund, thus achieving a more consistent approach.

Filed in Greek · English published by the European Commission

Finance Watch welcomes the holistic integration of the Do not Significant Harm (DNSH) principle into the next Multiannual Financial Framework (MFF). This approach builds on the continued integration of the DNSH principle into EU public finance architecture, as was the case under the Recovery and Resilience Facility, and more recently in the 2024 Financial Regulation.

A well-designed and technically robust EU Taxonomy can be a useful tool to steer investment towards more sustainable industrial activities. However, this requires criteria that reflect industrial realities and support Europes strategic objectives, such as secure access to critical raw materials, competitiveness, and affordable energy - something the current framework fails to achieve.

Pleasse find attached the full contribution of Seas At Risk to the Call for Evidence on applying the DNSH principle under the next MFF, it notably highlights the need to transform DNSH into a binding, enforceable eligibility condition across all EU funding instruments, ensuring that public spending is fully aligned with environmental objectives.

Please find below PGE Polska Grupa Energetyczna's key messages on the Guidance on applying the do no significant harm principle under the 2028-2034 multiannual financial framework. For specific comments please see the attached document. Key recommendations: The DNSH principle is currently applied in a fragmented, inconsistent, and overly detailed manner.

Whereas compliance with the DNSH principle is significantly neglected and needs to be significantly increased in the next MFF; Activities should be approved/rejected on the basis of whether they involve significant harm (and therefore do not qualify for EU funding) or whether they are expected to have such a limited environmental impact that EU funding can be granted.

Filed in Swedish · English published by the European Commission

Management Authority of National Program for Metropolitan and Southern Medium-Sized Cities 2021-2027 (PN Metro Plus) - Italian Department of Cohesion Policies The Management Authority of National Program for Metropolitan Cities and Southern Medium Sized Towns 2021-2027 (PN Metro) welcomes the European Commissions proposal to introduce a common methodology for applying the Do No Significant Harm (DNSH) principle…

COCIR is the European Trade Association representing the medical imaging, radiotherapy, health ICT and electromedical industries. Founded in 1959, COCIR is a non-profit association headquartered in Brussels (Belgium) with a China Desk based in Beijing since 2007.

The Institute for Agriculture and Trade Policy (IATP) Europe welcomes the application of the Do No Significant Harm (DNSH) principle across EU spending in the next long-term budget; however, we are concerned about the proposed blanket exemption of some farm subsidies from adhering to this principle.

A2A Group welcomes the opportunity to contribute to the European Commissions call for evidence on the application of the Do No Significant Harm (DNSH) principle in the context of the next Multiannual Financial Framework (MFF 20282034).

EQA is an international verification and certification organism, accredited by ENAC (spanish accreditation body) to validate DNSH criteria in Spain (www.EQA.org). EQA agrees with the Contribution to the Call for Evidence Guidance on the application of the Do No Significant Harm (DNSH) principle under the 20282034 MFF from the Spain Ministry for Ecological Transition and the Demographic Challenge.

CDP is the Italian National Promotional Institution (NPI) and one of the largest Italian financial institutions. CDP fosters sustainable development, growth, innovation, competitiveness, and infrastructure. CDP has a well-established experience in the implementation of EU spending programmes.

The Consellería do Mar de la Xunta de Galicia welcomes with utmost interest the development of a single and simplified document providing guidance on the application of the principle of do no significant harm (DNSH) in the 2028-2034 MFF. Galicia occupies a central position in the fisheries and aquaculture landscape of the European Union.

Filed in Spanish · English published by the European Commission

CIRF (Italian Center for River Restoration) welcomes the opportunity to contribute to the call for evidence for a guidance on the application of the do no significant harm (DNSH) principle under the 2028-2034 Multiannual Financial Framework (MFF).

For our full input, see attachment. Our recommendations are as follows: The Commission needs to step up environmental enforcement for all activities, not only EU-funded ones. The proposed guidance needs to clearly spell out the role of the do no significant harm assessment, clearly distinguishing its purpose and methodology from existing permitting procedures, as done under the RRF guidance but with more details on…

We attended the presentation given by the EC on 5 March. And we agree with all the areas of improvement identified by the EC. Below, we would like to highlight/elaborate on certain aspects that we considered to be insufficiently or incompletely addressed during this session on 5 March. — We would like to insist on receiving the DNSH draft guidelines before the May meeting.

Filed in French · English published by the European Commission

DNSH compliance in the next MFF may be assessed in two simple steps: First, activities are checked against two lists: an exclusion list (significant harm, no EU funding) and an eligibility list (no environmental impact foreseen). If an activity is on either list, it is automatically compliant or non-compliant, and the assessment ends. Most DNSH checks should be this simple.

Portuguese Experience in the Application of the DNSH Principle This contribution reflects the experience of national entities in applying the DNSH principle and the inputs collected under the coordination of the Ministry of Foreign Affairs, involving the bodies preparing the next programming period of the Cohesion Funds.

The European Banking Federation strongly supports the goal of simplifying and harmonizing the DNSH principle across the EU regulatory framework including its application under the MFF. We support all efforts for simplification, proportionality, practical applicability and consistency with EU law.

The purpose of the DNSH principle is to ensure that the investments financed do not cause significant harm to the six environmental objectives defined in Article 9 of Regulation (EU) 2020/852. There are currently no ‘amount thresholds’ below which the DNSH does not apply; evaluation is mandatory for aid and investments of any size, but the complexity of the documentation varies depending on the type of intervention.

Filed in Italian · English published by the European Commission

Terna welcomes the European Commissions initiative to develop a single, harmonised and simplified set of guidance for the application of the Do No Significant Harm (DNSH) principle under the next Multiannual Financial Framework (MFF), in line with Article 5 of the proposed Regulation on the performance framework for the EU budget.

The DNSH principle comes from the EU Taxonomy, which requires that activities contributing to one environmental goal do not harm the others. However, evidence shows that similar DNSH concepts are applied inconsistently across programmes, resulting in divergent outcomes.

Spains contribution is attached. The document reflects the extensive experience gained through the implementation of the RRF and highlights the essential role of the DNSH principle in ensuring the environmental integrity of EU funded investments.

Fincantieri is one of the worlds largest shipbuilding groups. We would like to share some reflections on the need to harmonise the application criteria of the DNSH principle. Inconsistent interpretation of DNSH principles across Member States risks creating unequal treatment and may undermine the effectiveness of financial instruments.

BUND - Bund für Umwelt und Naturschutz Deutschland (Friends of the Earth Germany) is an independent, federal NGO that has been dedicated to protecting nature and the environment since the mid-1970s. With over 674,000 members and supporters, 16 state organizations and 2,300 local and regional groups, BUND is one of the largest environmental associations in Germany today.

Compliance with the DNSH principle in the next MFF can be assessed in two simple steps. Firstly, the activities should be compared with two lists: an exclusion list (significant damage, no EU funding) and an eligibility list (no expected environmental impact). If an activity is present in one of the two lists, it is automatically compliant or non-compliant and the assessment is concluded.

Filed in Italian · English published by the European Commission

The Lithuanian Green Finance Institute, operating within the National Development Bank ILTE, welcomes the European Commissions initiative to develop a single and simplified DNSH guidance for the 2028-2034 MFF. We emphasize the importance of publishing the first draft before the summer break to finalize the document well ahead of the deadline of 1 January 2027.

The Italian National Cluster for Forest Forest Forest, representing the interests and specificities of the Italian forestry sector, would like to bring to the Commission’s attention a number of structural problems that have emerged from the implementation of the NRRP calls for proposals relating to ‘Contratti di Filiera Forestale’ and the forthcoming funding.

Filed in Italian · English published by the European Commission

The Community of European Railway and Infrastructure Companies (CER) welcomes the European Commission's initiative to develop guidance on the application of the 'do no significant harm' (DNSH) principle under the 2028-2034 Multiannual Financial Framework (MFF).

BETTER FINANCE supports a clear, simple and harmonised application of the Do No Significant Harm (DNSH) principle across the 20282034 EU budget. For retail investors and savers, the core expectation is straightforward: EU public money should not support activities that cause serious environmental harm, and the rules should be easy to understand, consistent across funds, and credible in practice.

The DNSH criteria should provide insight into the extent to which funds actually contribute to achieving set climate and environmental objectives, and into any negative externalities. The DNSH principle must be applied in a coherent and workable manner, whilst limiting the administrative burden.

The Region of Provence-Alpes Côte dAzur welcomes this call for evidence on the application of the DNSH principle in the context of the 2028-2034 MFF and wishes to give its opinion as managing authority for the ERDF, ESF + and JTF 2021-2027 funds.

Filed in French · English published by the European Commission

The purpose of the DNSH principle is to ensure that the investments financed do not cause significant harm to the six environmental objectives defined in Article 9 of Regulation (EU) 2020/852. There are currently no " threshold amounts " below which the DNSH does not apply; evaluation is mandatory for aid and investments of any size, but the complexity of the documentation varies depending on the type of…

Filed in Italian · English published by the European Commission

The Arbeitsgemeinschaft bäuerliche Landiwirtschaft supports the integration of the Do No Significant Harm (DNSH) principle across all EU budgetary spending in the next Multiannual Financial Framework. At the same time, we are deeply concerned by the proposal to exempt certain agricultural subsidies from complying with this standard.

Compliance with the DNSH principle in the next MFF could be assessed in two simple steps. First stage: the activities are compared with two lists: an exclusion list (significant damage, no EU funding) and a eligibility list (no expected environmental impact). If an activity appears on any of these lists, it is automatically compliant or non-compliant, and the assessment stops.

Filed in French · English published by the European Commission

This feedback is based on a soon-to-be-published analysis with the title The do no significant harm (DNSH) criteria: practical insights. The study was commissioned by the Austrian Federal Ministry of Agriculture and Forestry, Climate and Environmental Protection, Regions and Water Management and conducted by the Environment Agency Austria.

As part of the 2021-2027 ERDF programming period, the Campania Region adopted an organisational model and a structured procedural system for verifying the DNSH principle and the climate proofing criterion for infrastructure investments, based on the establishment of an office dedicated to verifying and complying with the DNSH and Climate Proofing principles.

Filed in Italian · English published by the European Commission

The Ministry of Climate and Energy of Latvia (hereinafter the Ministry) positively assesses the application of the principle Do No Significant Harm (hereinafter DNSH) to European Union funds investments, ensuring the assessment of climate and environmental related requirements in the planning and subsequent implementation process of investments.

T&E welcomes the initiative to streamline DNSH across the entire EU budget. We recommend the Commission to 1) Further build on the EU taxonomy and existing Social Climate Fund (SCF) guidance to design a simple and universally applicable guidance for the entire MFF, 2) Ensure that environmentally positive interventions (contributing to spending targets) adhere to the DNSH principle and that 3) The guidance results in…

1. Proposal to add to the list of exceptions list of DNSH application: 1.1. Civil protection is, by its nature and objectives, analogous to defence and security activities during emergencies, having the core mission of protecting and equipping the people; failure to explicitly mention it may lead to the provisions being applied incorrectly.

In order to ensure the effectiveness of the DNSH, its scope needs to be extended so that the principle applies to all financial instruments in the long-term budget of the European Union, including the financing of European Union activities in non-EU countries. In the interest of reducing administrative burden and legal clarity, the DNSH rules should be harmonised across all instruments.

Filed in Estonian · English published by the European Commission

For the design of the next Multiannual Financial Framework and in particular for the application of the principle of do no significant harm (DNSH). It is considered necessary to adopt a more proportionate and pragmatic approach to the application of the DNSH principle, based on the actual environmental risk of the actions, making it possible to simplify procedures for low-impact projects, ensure consistency with…

Filed in Spanish · English published by the European Commission

GD4S welcomes the Commissions initiative to establish clear and simple guidance for the Do No Significant Harm (DNSH) principle. As gas DSOs fully committed to integrating renewable gases into existing networks, we believe harmonised rules are essential to ensure EU funds effectively support the green transition without creating unnecessary administrative burdens.

The purpose of the DNSH principle is to ensure that the investments financed do not cause significant harm to the six environmental objectives defined in Article 9 of Regulation (EU) 2020/852. There are currently no ‘amount thresholds’ below which the DNSH does not apply; evaluation is mandatory for aid and investments of any size, but the complexity of the documentation varies depending on the type of intervention.

Filed in Italian · English published by the European Commission

The purpose of the DNSH principle is to ensure that the investments financed do not cause significant harm to the six environmental objectives defined in Article 9 of Regulation (EU) 2020/852. There are currently no ‘amount thresholds’ below which the DNSH does not apply; evaluation is mandatory for aid and investments of any size, but the complexity of the documentation varies depending on the type of intervention.

Filed in Italian · English published by the European Commission

The Regional Government of the Azores welcomes the European Commission’s objective to enhance clarity, consistency and legal certainty in the application of the ‘do no significant harm’ (DNSH) principle in the 2028 2034 MFF.

Filed in Portuguese · English published by the European Commission

The Febea Advocacy Lab (hereafter The Lab), a joint initiative between the European Federation of Ethical and Alternative Banks and Financiers and the Sustainable Banking Coalition, warmly welcomes the introduction of a single Do No Significant Harm (DNSH) principle guidance in the proposal on the Performance Framework Regulation.

The Spanish Confederation of Bus Transport (CONFEBUS) takes note of the public consultation on the ‘Do no significant harm’ (DNSH) guidance in the Multiannual Financial Framework 2028-2034. Confebus fully shares the European Union’s objectives of green transition and decarbonisation of the economy.

Filed in Spanish · English published by the European Commission

1. In the view of the Saxony ERDF/JTF managing authority, drawing up uniform guidelines could lead to considerable additional red tape for implementing bodies and beneficiaries. And – in view of the experience of the 2021-2027 funding period – without any discernible added value for the design and implementation of the programme or regional chapter. 2.

Filed in German · English published by the European Commission

The purpose of the DNSH principle is to ensure that the investments financed do not cause significant harm to the six environmental objectives defined in Article 9 of Regulation (EU) 2020/852. There are currently no ‘amount thresholds’ below which the DNSH does not apply; evaluation is mandatory for aid and investments of any size, but the complexity of the documentation varies depending on the type of intervention.

Filed in Italian · English published by the European Commission

There is a need to reduce the huge administrative burden created from the implementation of 3 environmental requirements (SEA, DNSH, Climate Proofing) for beneficiaries, environmental authorities and other involved stakeholders. This burden also causes delays to the implementation of projects. Suggestions for merging DNSH and C.P.

Zabala INNOVATION, an international consultant dedicated to the management of public aid and tax incentives since 1986, and which has managed with its clients more than 6.900 M in public aid over the last 5 years.

Filed in Spanish · English published by the European Commission

Please find attached a draft set of comments on the application of the DNSH principle in the CAP 2028-2034, drawn up also in the light of the operational evidence gathered by ARPEA. The document highlights, in particular, certain aspects of attention linked to the principle in the architecture of the CAP’s management and control systems, with specific reference to the potential impacts in terms of operational…

Filed in Italian · English published by the European Commission

When drawing up consistent guidelines on the application of the DNSH principle in the 2028-2034 financial perspective, account should be taken of the specific nature and material scope of projects applying for funding.

Filed in Polish · English published by the European Commission

“Confeuro expresses his full and firm support for the DNSH principles. We do not regard the protection of the environment, water resources and biodiversity as a mere regulatory constraint, but as the very precondition for the continuity of the farm business.

Filed in Italian · English published by the European Commission

— MFF payments may not lead to the conversion of permanent grassland, wetlands or land into Natura 2000 areas. — MFF payments shall not adversely affect habitat types or species listed in Annex I to Directive 92/43/EEC and species listed in Annexes II and IV to Directive 92/43/EEC.

Filed in German · English published by the European Commission

Below Estonia’s views, structured according to the areas of the different but relevant legislative initiatives of the MFF 2028+: 1. The performance framework for the European Union’s programmes and budget for the budgetary period 20282034 We do not significantly harm the integration of the DNSH principle into the EU budget, but its implementation needs to be clear and proportionate.

Filed in Estonian · English published by the European Commission

Iberdrola is happy to provide feedback to support the development of a single, clear and enforceable EU Do No Significant Harm (DNSH) guidance applicable across all EU funds. The company stresses that current approaches differ widely across instruments (Taxonomy Regulation, RRF, SCF, Cohesion Policy rules, and environmental directives), creating inconsistencies and administrative burden.

The Ministry of Economy welcomes the Do No Significant Harm (DNSH) approach in the European Commission’s Joint Research Centre report, based on the need to simplify the application of the DNSH principle as well as to reduce the administrative burden for Member States and beneficiaries.

Filed in Latvian · English published by the European Commission

We welcome the European Commission's initiative to harmonize and improve the application of the "do no serious harm" (DNSH) principle within the next Multiannual Financial Framework. This direction is particularly important from the perspective of reducing excessive administrative burdens and increasing regulatory coherence throughout the Union.

In the context of nature conservation, the DNSH principle is not too narrow in content, but it is too weak as the only decision standard, as it mainly acts as a minimum for preventing damage, while the national and EU nature protection system also requires the maintenance or restoration of favourable conservation status, effective project level control and caution in conditions of uncertainty.

The DNSH principle was complex to deploy over the period 2021-2027. In particular, the late approval of the Taxonomy Regulation in June 2020 was a challenge, as the scheduling of programmes was already well advanced by that date. It therefore seems necessary for the European Commission’s guidelines to be known as soon as possible, ideally before 1 January 2027.

Filed in French · English published by the European Commission

FederUnacoma welcomes the European Commissions initiative to develop unified and simplified guidelines for the application of the do no significant harm principle within the 20282034 Multiannual Financial Framework (MFF). However, it should be noted that in the recent past, the application of the DNSH principle has generated significant challenges.

Non-ferrous metals are a key enabler of the twin green and digital transition in the EU. With the demand for these materials expected to grow significantly by 2050, increasing domestic supplies of critical raw materials (CRMs) and other valuable metals must remain a priority of upcoming EU legislation and be facilitated through relevant EU funding instruments covered both within and outside of the 2028-2034…

EERA Response to the European Commission Implementing the Do No Significant Harm (DNSH) Principle The European Electronics Recyclers Association (EERA) welcomes the European Commission's initiative to develop harmonised guidance on the application of the Do No Significant Harm (DNSH) principle under the 2028-2034 Multiannual Financial Framework (MFF).

WWF Italy welcomes the opportunity to participate in the call for evidence on the Do No Significant Harm (DNSH) principle in the framework of the next Multiannual Financial Framework (20282034). Please find attached our contribution to the consultation.

The European Environmental Bureau (EEB) welcomes the opportunity to contribute to the call for evidence regarding guidance on the application of the 'do no signifcant harm' principle under the 2028-2034 MFF. Please find attached our detailed contribution, which includes a feedback on the Commission's proposal for an EU Budget Performance Regulation, as well as input on the future Commission guidance.

The Association of Urban Municipalities of Slovenia (Združenje mestnih občin Slovenije ZMOS), representing the 12 urban municipalities of Slovenia and being involved in the implementation of the Integrated Territorial Investments mechanism for sustainable urban development, wishes to provide a response to the call for evidence regarding the application of the DNSH principle in the next multiannual financial…

As an expert (civil servant) involved in the preparation of public calls (especially those related to the JTF) during the MFF period 2021-2027, here are my observations regarding the DNSH and current guidelines: - The current guidelines on Do No Significant Harm (DNSH) are quite vague, providing various options for implementation.

FuelsEurope welcomes the European Commissions intention to introduce a common methodology for applying the Do No Significant Harm (DNSH) principle across policy areas within the 20282034 Multiannual Financial Framework (MFF).

EDFIs call for greater consistency and proportionality in the application of the Do No Significant Harm principle across EU budgetary and regulatory frameworks, including through mutual recognition between regimes, to avoid duplicative assessments while ensuring a context sensitive approach to EU external action. What we are recommending on Do No Significant Harm (DNSH).

The development of a single and simplified guidance for the application of the DNSH principle across EU funding instruments is a welcome initiative, particularly in light of the current fragmentation and heterogeneity of approaches highlighted in the consultation document.

GÉANT welcomes the European Commissions call for evidence on the application of the Do No Significant harm (DNSH) principle under the 2028-2034 MFF. Based on our experience in applying the DNSH principle within a coordination and support context, we propose the following seven recommendations for the DNSH guidance for the 2028-2034 MFF: (1) Provide tailored DNSH guidance for low-impact projects: Develop specific…

Repsol welcomes the European Commissions call for evidence on the application of the do no significant harm (DNSH) principle under the 20282034 Multiannual Financial Framework and appreciates the opportunity to contribute to this important initiative. As a key horizontal safeguard, DNSH plays a central role in ensuring that EU funding supports the green transition while preserving environmental integrity.

IUCN welcomes the planned horizontal approach to apply the Do No Significant Harm (DNSH) principle to the 2028-2034 Multiannual Financial Framework. Due to its previous applications since the Recovery and Resilience Facility, various lessons learned might inform the design of this new horizontal approach.

The Do No Significant Harm (DNSH) principle is already applied across several EU funding programmes, albeit in a non-harmonised manner. Acea welcomes the European Commissions initiative to streamline and harmonise its application under the Multiannual Financial Framework (MFF) 20282034, while highlighting key challenges experienced during the 20212027 period.

The rationale behind this short feedback is providing the experience-based inputs in order to promote a clearer, more proportionate and non-duplicative approach on how DNSH could be applied in 2028-2034 programming period. LEGAL BASIS AND COMPLIANCE: The DNSH principle was born with the Taxonomy Regulation, aiming to classify economic activities by environmentally sustainable investments.

As a European environmental association, we welcome the simplification of the * * Do No Significant Harm (DNSH) principle * * in the upcoming * * Multiannual Financial Framework (MFF) * *. However, we are deeply concerned that the current proposal for the * * Common Agricultural Policy (CAP) * * risks undermining both the credibility and the effectiveness of the DNSH principle. # # # Key Concerns 1.

Filed in Italian · English published by the European Commission

SEA Europe strongly opposes the approach proposed by the European Commission for the forthcoming DNSH guidance. Guidance documents should serve a clear and limited function: they should provide operational clarification and practical explanations to facilitate consistent implementation of rules already established in EU legislation.

BLOOM is a European NGO founded in 2005 by Claire Nouvian and based in Paris and Brussels. Its mission is to protect the ocean and its inhabitants by working for the common good and to preserve biodiversity. We consider that the future DNSH guidance under the 2028 to 2034 MFF must function as a real filter against harmful spending, not as a procedural formality.

Fossil fuel subsidies are fundamentally incompatible with the DNSH principle, as they perpetuate environmental harm, distort markets, and contradict the EUs commitment to climate neutrality by 2050. The 8th Environmental Action Programme and, more recently, the Advisory Opinion of the International Court of Justice (2025) both underscore the need to phase out fossil fuel subsidies without delay.

We welcome the proportionality and appropriateness approach envisaged in the revision of the DNSH guidelines for the 2028-2034 MFF, as well as the planned uniform implementation of the DNSH principle across the EU.

Filed in German · English published by the European Commission

For the Fédération Nationale Bovine, the ‘do no significant harm’ (DNSH) principle does not apply to national and regional partnership plans (NRPP), and in particular the common agricultural policy (CAP). NRPP, and in particular the CAP, are already subject to stringent environmental conditionality, through the protective practices proposed in the post-2027 draft CAP.

Filed in French · English published by the European Commission

Based on the experience gained, as well as the first applications of DNSH in other instruments (in particular the NRRP), a number of challenges emerge: uneven application across funds; strong documentary formalism; late and unclear arrival of guidelines; overlaps with sectoral permits, slowing down and discouraging investments, especially small-scale ones.

Filed in Italian · English published by the European Commission

While agreeing with the aims of the DNSH principle, considering it an essential tool for directing public spending towards climate and environmental objectives, it stresses the need for its application in the agricultural sector to be simple, proportionate and compatible with the typical regional production structure, characterised by small and medium-sized farms and large rural and inland areas.

Filed in Italian · English published by the European Commission

MIRA Network ringrazia la Commissione europea per lopportunità di contribuire alla consultazione pubblica sulla guidance per lapplicazione del principio Do No Significant Harm (o DNSH) nel QFP 20282034. Riteniamo che tale principio sia centrale per lintegrità ambientale del bilancio UE, e che si inserisca nella traiettoria strategica della Commissione in materia di obiettivi climatici e ambientali.

Implementation of DNSH principle is problematic, as guidance essentially establishes a sustainability assessment, which may be extensive as well as streamlined to the current climate and environmental legislative framework. There are several methodologies which overlap in their objectives, the scope of application is not coherent between the EU funds legislation.

The nova-Institute and TAURUS Eco Consulting welcome the European Commissions initiative to develop a single and simplified guidance for applying the Do No Significant Harm (DNSH) principle under the 20282034 Multiannual Financial Framework (MFF). Preventing environmental harm remains both an ecological and economic necessity and a prerequisite for sustainable development in line with Article 11 TFEU.

In general, the DNSH principle is entirely acceptable, since it is intended to ensure that the environment and the land are resilient in favour of future generations. In the agricultural sector in particular, the principle has been put into practice for many years, linking the receipt of EU contributions to stringent (and sometimes unsustainable) environmental requirements.

Filed in Italian · English published by the European Commission

The Czech Chamber of Commerce applies the following: When preparing and applying the guidance under Article 5 of the proposed Performance Regulation, it is appropriate to emphasise that the principle of ‘do no significant harm’ (DNSH) is interpreted and applied in a way that does not lead to undue interference with the legitimate interests of citizens and entrepreneurs.

Filed in Czech · English published by the European Commission

Italgas welcomes the European Commissions initiative to develop a single and simplified guidance for the application of the Do No Significant Harm (DNSH) principle under the 20282034 Multiannual Financial Framework.

Ref: European Commission launches Call for Evidence on the application of the Do No Significant Harm principle in the next MFF. In addition to the objectives that the new guidance "Do No Significant Harm principle in the next MFF" is expected to provide, we identified the following: - provide a single set of criteria for assessing compliance with DNSH across Union funds; - distinguish between activities that are…

The DNSH analysis was complex to understand for the 21/27 programmes since – this requirement arrived late – it was not accompanied by technical details in order to assess objectively the 6 criteria. In order to harmonise the work, a national grid was drawn up to identify the various laws and regulations governing these criteria, followed by a thematic analysis.

Filed in French · English published by the European Commission

Proving of DNSH is especially for SMEs and other small entities extremely burdensome as the cost benefit analysis commissioned by DG GROW on taxonomy for SMEs has proved. Therefore, the 2nd Platform on Sustainable Finance rightly recommended in its streamline approach of sustainable finance for SMEs that SMEs which work in Europe and fulfil all legal requirements are not doing significant harm as long as they are…

The application of the ‘do no significant harm’ principle has had a significant positive impact on the EU’s multiannual budget period of 21.27 years, raising awareness and preventing or mitigating the negative impacts of investments.

Filed in Latvian · English published by the European Commission

The do no significant harm (DNSH) principle should become a robust and consistently applied eligibility condition across the 20282034 Multiannual Financial Framework (MFF). Experience from the current MFF and from recovery instruments demonstrates that DNSH has often been applied unevenly across funds, sectors and implementation channels.

Given that proportionality needs to be ensured when applying the DNSH principle, Interreg chapters should be excepted from applying the do no significant harm principle. The activities implemented under Interreg chapter are always reduced in size and in climate and environmental impacts.

The DNSH principle was very difficult to implement when the 2021-2027 programmes were drawn up, but also subsequently at the level of their management. The most logical approach was to assess it at the level of each measure. But the best performance would have been to check it once, a priori, at programme level. The idea is to assess DNSH at the level of a programme, policy, scheme etc.

Filed in French · English published by the European Commission

Latvia’s experience in applying the Do No Significant Harm (DNSH) principle under the European Agricultural Fund for Rural Development (EAFRD) for investment measures under the Rural Development Programme 2014-2020 (with a transitional period until 2022) has shown that the previous approach has been simple, proportionate and practically applicable.

Filed in Latvian · English published by the European Commission

The Consell General de Cambres de Comerç de Catalunya welcomes the European Commissions initiative to provide technical guidance on the application of the Do No Significant Harm (DNSH) principle in the next Multiannual Financial Framework. Clear and consistent guidance will be essential to ensure effective implementation while maintaining accessibility of EU funding for businesses, particularly SMEs.

We propose to merge the concepts of ‘climate immunisation’ and ‘DNSH’ into an integrated legal framework, harmonised with environmental legislation. Both concepts share two components – climate change mitigation and climate change adaptation.

Filed in Romanian · English published by the European Commission