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25 February 2019

Usability of the taxonomy: EBF responds to European Commission’s Technical Expert Group consultation

Taxonomy should be seen as a common language that could be applied by all (financial and non-financial) market participants to all their activities. The usability of the taxonomy will depend mainly on the way the taxonomy will be implemented, the EBF reminded the Commission.

Automatization of the processes and integration into the IT systems has a great potential for acceptance, successful adoption and implementation of the taxonomy. Taxonomy should be a system with well-defined environmental activity codes, which can be used to originate financial products, to make automated selections of investments or to verify compliance of these with the taxonomy.

A first KEY element of usability is alignment of the Taxonomy with existing economic activity classifications, to the maximum extent possible.

A second KEY element of usability is alignment of the Taxonomy with existing environmental classifications to the maximum extent possible.

The point of the taxonomy should be to define what part of an activity can be deemed sustainable. The existing NACE codes will never be sufficient for this purpose; therefore it is necessary to use additional codes for the purpose.

EBF suggests:

  • Using and expanding existing activity classifications including NACE, of the revised European system of integrated statistical classifications, the which distinguishes between activities (NACE), products (CPA) and goods/services (PRODCOM/CN); and
  • Classifying each of them into 16 environmental CEPA/CReMA purposes/domains.

A third KEY element of usability is alignment of environmental disclosures. Sustainable Finance Taxonomy must be fully aligned with the taxonomy for the Environmental Accounts of the Member States, otherwise Member States will report different environmental investment figures than those of Financial Market Participants.

A fourth KEY element of usability is its applicability. It is important to distinguish between voluntary and mandatory use of the taxonomy. It should be possible for all market participants to apply the taxonomy as a common comprehensive framework or classification system to all activities, products and services on a voluntary basis while requiring the financial products, marketed, to be sustainable.

A fifth KEY element of usability is the possibility to implement the taxonomy in ICT systems and work processes. EBF encourages and support a system of robust classifications and codes that can be used in an automated way.

A sixth KEY element of usability is the threshold. EBF recommends to leave it to the market the definition of these thresholds, and only describe the process of how market participants can define thresholds, and the management and documentation of the results.

The seventh KEY element is the application of the do no harm assessment. It  should be allowed, as an alternative, to assess the sustainability at the level of the investee companies and borrowers.

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