We welcome the proposal to maintain double materiality as the basis for ESRS reporting (ESRS 1, 3.1) We note that the removal of specified metrics for ESRS E4 will cause companies to expend time and resources to identify appropriate metrics.
IUC
IUCN
Environmental organization · Switzerland · EU Transparency Register 03518238467-61
4
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1107 non-governmental organisations on this site, they rank #353 by legislative files engaged, a count of participation, not a measure of influence.
3.5
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2012
in the register since
Declares membership of
- Relevant IUCN membership includes, inter alia:
- Forum for the Future of Agriculture
- Circular Economy Stakeholder Platform
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- International Union for Conservation of Nature EU Representative Office (IUCN EURO)
- Head office
- Brussels, Belgium
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
IUCN filed 4 positions between 1 Aug 2025 and 3 Jun 2026, across 4 of the 665 legislative files tracked here, attaching a full position paper 1 time.
2025 · 2 filed2026 · 2 filed
What they argued
The EU Biodiversity Strategy for 2030 sets out ambitious targets for conserving and restoring nature, underscoring the crucial role of sufficient and sustainable financing. While the initial funding gap was estimated at EUR 20 billion annually, this figure has since been revised upward to EUR 48 billion per year, even before factoring in the financial demands introduced by the Nature Restoration Regulation.
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 International Union for Conservation of Nature (IUCN) acknowledges the European Commissions proposal to simplify the implementation of the Common Agricultural Policy (CAP). IUCN recognises the importance of reducing administrative burdens for farmers and administrations, and underlines that such simplifications should not come at the expense of environmental safeguards and policy coherence.
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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.
Showing 5 of 70.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.