Dear European Commission FISMA team, Thank you for the opportunity to provide feedback on the EU Taxonomy environmental and climate delegated acts. As actors in the real estate sector, we welcome the Commissions efforts to improve clarity and usability. Our comments focus mainly on part 3 of the Environmental Delegated Act, with targeted links to part 7 of the Climate Delegated Act where criteria overlap. 1.
ATE
Atenor
Company · Belgium
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 657 files tracked
2
legislative files
of 657 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 657 consultation files tracked so far (57,479 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Atenor filed 2 positions between 4 Dec 2025 and 1 Jun 2026, across 2 of the 657 legislative files tracked here, attaching a full position paper 2 times.
2025 · 1 filed2026 · 1 filed
What they argued
Atenor Position Summary on the Draft Delegated Act amending ESRS (May 2026) Atenor welcomes the simplification effort reflected in the Draft Delegated Act of 6 May 2026 notably the top-down DMA approach, the extended phase-ins, and the 'undue cost or effort' relief. However, structural requests remain entirely unaddressed. 1.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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