| A | Taxonomy Clarity and Inclusivity |
The importance of having a clear and comprehensive taxonomy that includes a broad range of market activities for sustainable economic transition, ensuring it is understandable to avoid confusion. |
| 1 | Clarity in taxonomy |
The necessity for clear and understandable criteria in the taxonomy to avoid confusion. |
| 2 | Taxonomy inclusivity |
The need for the taxonomy to include a broader range of relevant market activities for sustainable economic transition. |
| B | Sustainable Finance and Metrics |
The need for sustainable finance to be widely distributed across industries with clear and comprehensive metrics for evaluating sustainability and life cycle analysis. |
| 3 | Sustainable finance distribution |
The necessity for sustainable finance to be accessible across various industries, rather than being limited to specific sectors. |
| 4 | Sustainability metrics and analysis |
The need for clear and comprehensive metrics and life cycle analysis to evaluate sustainability across different sectors. |
| C | Sustainability Evaluation and Distinction |
The importance of adopting appropriate methods for evaluating the performance of buildings and investments, with a focus on sustainability, and differentiating between environmentally sustainable activities and those that are merely energy efficient. |
| 5 | Distinction in sustainability |
The need to differentiate between environmentally sustainable activities and those that are energy efficient but not sustainable. |
| 6 | Performance evaluation methods |
The importance of adopting appropriate methods for evaluating the performance of buildings and investments, emphasizing ex-post approaches. |
| D | Renewable Resources in Industry |
Exploring the role of renewable resources like sustainable biomass in various industry sectors and the need for sector-specific criteria to enhance sustainability. |
| 7 | Sustainable biomass |
Importance of sustainable biomass as renewable feedstock for various sectors. |
| 8 | Sector-specific manufacturing |
Need for tailored criteria for different manufacturing sectors based on regional characteristics. |
| A | Sustainability Assessment Criteria Challenges |
Concerns regarding the restrictiveness and prescriptiveness of sustainability assessment criteria that may limit investment opportunities and hinder innovation. |
| 1 | Prescriptiveness and innovation |
The potential hindrance to innovation and future developments due to overly prescriptive criteria in sustainability assessments. |
| 2 | Restrictiveness of criteria |
Concerns that overly strict criteria may limit investment opportunities for institutional investors. |
| B | Sustainability Taxonomy Clarity and Implementation |
The need for clearer sustainability classifications and the challenges of implementing systems like the NACE classification, including administrative burdens and the importance of stakeholder communication. |
| 3 | Stakeholder communication |
The importance of a clear taxonomy for effective dialogue with stakeholders, particularly investors. |
| 4 | Administrative burden |
The complexity and potential high costs associated with implementing the NACE classification for financial market participants. |
| 5 | Clarity of classification |
The need for clearer definitions and classifications in sustainability assessments to avoid confusion. |
| C | ESG Data Handling and Quality |
Issues related to the availability, quality, and verification of data for sustainability assessments, as well as the challenges in aggregating this data for stakeholders. |
| 6 | Data Aggregation Challenges |
Issues surrounding the aggregation of data required by stakeholders, including consistency with existing legislation and local circumstances. |
| 7 | Data availability challenges |
Issues related to obtaining detailed and granular information from issuers for sustainability assessments. |
| 8 | Data quality and verification |
Concerns about the resources and methods required for data verification and quality assurance in financial reporting. |
| D | Sustainability Impact and Innovation Assessment |
Difficulties in measuring the environmental impact of activities and the challenge of assessing innovative technologies without impeding their development. |
| 9 | Assessment of Innovative Technologies |
The challenge of assessing projects integrated into traditional industrial processes to avoid hindering innovative technologies aimed at reducing carbon emissions. |
| 10 | Impact measurement challenges |
Difficulties in demonstrating and calculating the environmental impact of activities and investments. |
| E | Taxonomy Adaptation and Coherence |
The necessity of adapting taxonomy to various contexts, including geographical factors, SME inclusion, and ensuring alignment with broader EU policies. |
| 11 | SME Inclusion in Taxonomy |
The need for taxonomy to accommodate small and medium-sized enterprises (SMEs) to ensure they can participate as sustainable investee companies. |
| 12 | Geographical context in taxonomy |
The necessity of considering geographical and contextual factors in determining what is environmentally sustainable. |
| 13 | Coherence with EU Policies |
The necessity for taxonomy to align with broader EU policies on climate change, bioeconomy, and circular economy. |
| F | Sustainability Taxonomy and Regulation Challenges |
The complexities of integrating sustainability taxonomy within regulatory frameworks, including the importance of impact assessments and the unique features of lending activities. |
| 14 | ESG risk identification |
Challenges in identifying and mitigating ESG risks within specific sectors. |
| 15 | Lending Activities and Taxonomy |
The need to separately assess the applicability of taxonomy to lending activities, considering their unique features. |
| 16 | Impact Assessment in Regulation |
The importance of impact assessments and expert representation in the drafting of delegated acts related to taxonomy. |
| A | Regulatory Compliance and Clarity |
The taxonomy should be clearly distinguished from disclosure regulations while ensuring alignment with EU legislation and integration with disclosure requirements to avoid conflicts and maintain relevance. |
| 1 | Alignment with Legislation |
The taxonomy should align with existing EU legislation and regulations to ensure compliance and relevance. |
| 2 | Integration with Disclosure Requirements |
The taxonomy should be integrated as a reference for evaluating green activities and revenues in compliance with disclosure requirements. |
| 3 | Distinction Between Taxonomy and Disclosure |
There should be a clear distinction between the taxonomy and disclosure regulations to avoid conflicts and overlaps. |
| B | Taxonomy Usability and Precision |
The taxonomy should be user-friendly, understandable for all stakeholders, and provide an appropriate level of detail in sustainability disclosures to balance precision and usability. |
| 4 | User-Friendliness |
The taxonomy should be designed to be user-friendly and understandable for various stakeholders, including SMEs, citizens, and NGOs. |
| 5 | Granularity of disclosure |
The need for an appropriate level of detail in sustainability disclosures to balance precision and usability. |
| C | Environmental Impact Reporting |
The taxonomy should prioritize an impact-based approach and ensure transparency in environmental performance reporting to prevent green-washing and enable meaningful comparisons. |
| 6 | Impact-Based Approach |
The taxonomy should incorporate an impact-based approach to reporting, focusing on measurable environmental impacts rather than just economic activities. |
| 7 | Transparency in Environmental Reporting |
The need for clear and effective transparency in environmental performance reporting to prevent green-washing and ensure meaningful comparisons. |
| D | Dynamic Taxonomy for Evolving Practices |
The taxonomy should be adaptable to frequently incorporate new technologies and practices, and support the classification of investments related to industrial synergies. |
| 8 | Adaptability of Taxonomy |
The necessity for the taxonomy to be revised frequently to keep up with new technologies and practices. |
| 9 | Support for Industrial Synergies |
The taxonomy should facilitate the classification of investments related to industrial synergies, ensuring that financial classifications support interconnected processes. |
| A | Taxonomy Precision and Flexibility |
The necessity for a taxonomy that is both precise in its definitions to prevent misclassification and adaptable enough to suit various sectors within the banking and finance industry. |
| 1 | Clarity of definitions |
The need for clearer and more specific definitions in the proposed taxonomy to avoid misunderstandings and misclassifications. |
| 2 | Granularity in reporting |
The requirement for a more detailed and specific classification system for better reporting and understanding of low carbon sectors. |
| 3 | Taxonomy Flexibility |
The need for a more adaptable taxonomy that accommodates various segments of the banking and finance industry. |
| B | Sustainable Investment Dynamics |
The interplay between financial considerations and environmental sustainability in investment decisions, emphasizing the need for transparency and the challenges faced in implementing a green taxonomy. |
| 4 | Sustainability Transparency |
The need for companies to be transparent about the sustainability of their activities, considering the full life cycle of products and services. |
| 5 | Taxonomy Implementation Challenges |
Concerns regarding the practical implementation of taxonomy and the potential gap between expectations and reality in investment standards. |
| 6 | Investment considerations |
The importance of financial return and risk in investment decisions, overshadowing environmental sustainability unless clear implications are established. |
| C | Other topics |
Topics which could not be grouped into themes. |
| 7 | Inclusive Energy Transition |
The importance of including all technologies in the energy transition, recognizing diverse energy mixes and the role of liquid fuels. |