Simply Sustainable Finance: Understanding the Do-No-Significant-Harm (DNSH) Principle

Navigating the landscape of sustainable finance requires a solid grasp of regulatory concepts and principles. Whether you’re a policymaker, financial institution, business, or investor, understanding these frameworks is crucial for aligning with Europe’s ambitious climate and sustainability objectives.

The Do-No-Significant-Harm (DNSH) principle is a key element of the European Union’s framework for sustainable finance, specifically under Article 3 of the Taxonomy Regulation.

This principle requires that for an economic activity to be deemed environmentally sustainable, it must not only substantially contribute to one or more of the environmental objectives set out in Article 9 of the Taxonomy Regulation, but also, the relevant activity cannot not significantly harm any of the six environmental objectives. These objectives guide the sustainable development goals within the EU, ensuring that efforts to promote sustainability in one area do not inadvertently cause damage in another.

The Six Environmental Objectives Established by the Taxonomy Regulation

  1. Climate Change Mitigation
  2. Climate Change Adaptation
  3. The Sustainable Use and Protection of Water and Marine Resources
  4. The Transition to a Circular Economy
  5. Pollution Prevention and Control
  6. The protection and Restoration of Biodiversity and Ecosystems


Article 17 of the Taxonomy Regulation defines what “significant harm” to each of the six environmental objectives foreseen in the Taxonomy Regulation means:

Environmental objective
Significant harm
Climate change mitigationActivity leading to significant greenhouse gas emissions
Climate change adaptationActivity leading to an increased adverse impact of the current climate and the expected future climate, on the activity itself or on people, nature or assets
The sustainable use and protection of water and marine resourcesThe activity is detrimental to the good status or the good ecological potential of bodies of water, including surface water and groundwater; or to the good environmental status of marine waters
The transition to a circular economy

Activity leading to significant inefficiencies in the use of materials or in the direct or indirect use of natural resources such as non-renewable energy sources, raw materials, water and land at one or more stages of the life cycle of products, including in terms of durability, reparability, upgradability, reusability or recyclability of products

Activity leading to a significant increase in the generation, incineration or disposal of waste, with the exception of the incineration of non-recyclable hazardous waste

Activity where the long-term disposal of waste may cause significant and long-term harm to the environment

Pollution prevention and controlActivity leading to a significant increase in the emissions of pollutants into air, water or land, as compared with the situation before the activity started
The protection and restoration of biodiversity and ecosystemsThe activity is significantly detrimental to the good condition and resilience of ecosystems; or is detrimental to the conservation status of habitats and species, including those of Union interest

 

Under the Climate Delegated Act, specific requirements are outlined to ensure that economic activities do not cause significant harm to any of the environmental objectives, particularly those not directly related to climate, such as water protection, circular economy, pollution control, and biodiversity.

The ENGAGE Templates V1.1 incorporate a specific section on the DNSH principle covering the economic activity of acquisition and ownership of buildings.

If you want to discover how the ENGAGE Templates V1.1 have integrated the DNSH principle requirements, contact the ENGAGE for ESG team at engage4esg@eurodw.eu

European lending institutions are encouraged to test the ENGAGE Templates for free until October 2025 and can request them by clicking here.

Become an ENGAGE Pilot

To receive the ENGAGE Templates, lending institutions are required to complete a simple access request form available via the ENGAGE for ESG websiteOnce the request is processed, the applicant will receive the Templates and supporting documentation via email.

In a 30-minute meeting, the ENGAGE Team will walk you through the nuances of the ENGAGE Templates and demonstrate how they will help lending institutions identify the relevant climate-related data to align their mortgages and home renovation loans with the EU Taxonomy in line with the Technical Screening Criteria of the Climate Delegated Act for the economic activities of acquisition and ownership and renovation of real estate.

Sign the ENGAGE agreement to receive the sample data submission files. A specific legal framework has been prepared for the safe and lawful processing of data.

Complete the ENGAGE Templates and submit your mortgage sample file to the ENGAGE Portal.

Receive the ENGAGE report on EU Taxonomy compliance.