6.4.2022
EN
Official Journal of the European Union
C 152/101
4.1.5.
The delegated act already provided for in the Taxonomy Regulation to cover the remaining four environmental objectives in the areas of water, biodiversity, pollution prevention and the circular economy (Action 1d) is a welcome step towards a holistic approach to sustainability.
The EESC also welcomes the Commission’s announcement that it will propose assessment criteria in relation to biodiversity in order to link it with climate policy.
The extension to economic activities with an intermediate level of environmental performance as well as the differentiation between economic activities with no significant impact on environmental sustainability and economic activities that significantly harm environmental sustainability (Action 1b) are steps in the right direction.
The Taxonomy Regulation provides for a report to be published on economic activities with and without a significant impact by the end of 2021.
The EESC calls for this deadline to be met.
In expanding the taxonomy, care must also be taken to ensure that there are no loopholes for greenwashing, not least because of greater complexity.
4.1.6.
The EESC welcomes the extension of standards and labels (Action 1e) and calls for greater determination in the introduction of minimum standards, among other things.
It is important to have a general framework for a label for financial instruments to fund the transition so that there are clearly defined and reliable reference points.
Deceptive ‘sustainability-washing’, whereby an institution pretends to be more environmentally or socially sustainable than it actually is, deserves extra attention.
However, only an assessment of whether this is necessary is expected by 2023.
When it comes to the creation of an ESG benchmark, too, only an assessment was announced, even though — here as well — binding definitions and rules would be important building blocks for providing the clarity that investors and society are rightly calling for.
4.2.
An inclusive framework for sustainable finance 4.2.1.
The EESC welcomes the objective of making it easier for consumers, retail investors and SMEs to access sustainable finance so as to facilitate smaller projects at local level (Action 2a).
To that end, it must also be ensured that financing costs are fair.
Promoting knowledge of sustainability is a good approach that responds to the growing interest.
However, financial education can never replace sound investor protection, and the emphasis on sustainability aspects must not lead to disproportionately high risks being concealed.
Investor representatives must be involved in the development of a financial competence framework.
4.2.2.
To improve sustainability reporting, including for SMEs not covered by the Proposal for a Corporate Sustainability Reporting Directive (CSRD) (9), the EESC welcomes the advisory and taxonomy compass projects (Action 2a).
Better and more binding reporting is important as the economic activities of smaller companies can also have significant environmental impacts.
The EESC points out that civil society as a whole has a strong interest in sustainable company policy.
In particular, customers of and investors in SMEs will also ask for sustainability declarations.
However, with a simplified ESG reporting system, care must be taken to prevent greenwashing.
Moreover, the following steps are recommended: standardise and compare the non-financial information of EU companies, implement a regulatory and supervisory framework for providers of sustainability data and ensure access to companies’ non-financial raw data.
Reporting requirements are not an end in itself and should therefore not entail excessive resources and costs, but be effective in contributing to transparency in order to improve market efficiency and thereby facilitate better access to finance.
4.2.3.
The use of digital technologies for sustainable finance is consistent.
By the same token, sustainability aspects must be embedded into technologies (Action 2b).
Coordinating measures to promote holistic sustainability and digitalisation and to tackle the COVID-19 crisis create synergies that need to be enhanced, thus giving EU action more weight.
The EESC recommends linking green budgeting (Action 2e) with a future golden rule for investments.
Overall, it is regrettable that there is no holistic approach to sustainability here either.
In the case of risk-sharing, care must be taken to ensure that there is no one-sided burden and risk transfer to the detriment of the public sector.
4.2.4.
The increase in insurance coverage in relation to environmental risks constitutes an adaptation to the current situation.
According to the Commission, a slight increase can significantly reduce the cost of climate-related disasters for taxpayers and governments, which the EESC warmly welcomes.
However, the proposed steps, including identifying best practice examples, seem to be incredibly defensive.
In any case, social partners and civil society must be involved in a dialogue on climate and overall resilience.
(9)
Proposal for a directive as regards corporate sustainability reporting (COM(2021) 189 final).