1. European industry is at the core of the environmental and energy transformation. Access to investments will be of critical importance to make it successful. The European business community is therefore supportive of the objective of the Sustainable Finance Action Plan to further mobilise investments in the EU in view of achieving sustainable growth, job creation and prosperity.
2. We support the idea of creating a level playing field for so-called "green" financial products and to provide greater clarity to the markets through a more coordinated EU approach. A well-designed taxonomy could contribute to these goals and help to establish a common language for Sustainable Finance.
3. Therefore, the taxonomy should
• harmonise existing standards rather than establishing new standards.
• keep a flexible approach that prevents prescriptive categories which do not take the dynamic evolution of technology into account.
• not lead to additional bureaucratic burden.
• be accompanied by mechanisms that ensure it will not be misused as punitive instrument.
The link between the taxonomy and other EU legislations must be strictly defined in the proposal to avoid future ill-conceived initiatives.
We suggest in line with the better regulation principles to have a rigorous discussion with all stakeholders, including representatives from the real economy in order to set up a comprehensive regulation. Main criteria should be clarified in the regulation itself and not in delegated acts. This is essential to set up a balanced and easily applicable taxonomy that will be accepted by market participants.