IOGP Europe response to the EU Taxonomy – review of Climate and Environmental Delegated Acts consultation

IOGP Europe welcomes the review of the Climate and Environmental Delegated Acts. We support the Commission’s objective to simplify the EU Taxonomy in line with the Competitiveness Compass and the Omnibus I simplification package, and we provide evidence focused on improving clarity, legal certainty and proportionality. This submission responds to the Commission’s call for evidence on the review of both the Climate and Environmental Delegated Acts.

Experience applying the Technical Screening Criteria (TSC) shows that many elements remain difficult to operationalize, especially where requirements are granular, ambiguous or based on assumptions that do not reflect how projects are assessed, permitted or managed in jurisdictions with different regulatory systems. Companies also face disproportionate administrative burdens in Do No Significant Harm (DNSH) assessments, in particular in early project stages when data is limited and also on small scale/geographically distributed assets and activities that are not core to business operations or significant to environmental impact. For example, early-stage Life Cycle Assessments (LCAs) and long-term climate projections (e.g. estimating conditions in 2050 or 2060) are often not feasible at the early stages of a project, such as during conception or permitting stages. This also affects activities with a very small environmental footprint, such as individual charging points, which are subject to the same criteria as large low-carbon public transport infrastructure (such as tram or metro systems) under Activity 6.15, despite their non-comparable impact.

Addressing these issues through clearer, more proportionate criteria aligned with established national frameworks would improve consistency and reduce unnecessary complexity while maintaining environmental integrity. These challenges reflect consistent implementation issues, where overly detailed criteria and unclear expectations increase compliance risks without delivering better environmental outcomes.

This submission outlines practical adjustments to strengthen usability, support investment, and ensure alignment with evolving EU legislation. We focus on improving interoperability with strong non-EU regulatory systems and on ensuring that the criteria reflect how energy and industrial projects are planned, permitted and operated in practice across different regions and technologies. We recommend clearer guidance on Minimum Safeguards applied at the reporting-entity level and a more explicit proportionality principle to avoid disproportionate requirements for activities incidental or peripheral to an undertaking core business. We also strongly encourage the Commission to ensure technology neutrality across activities, avoiding selective criteria that create inconsistent burdens.

Download the document to see our full list of recommendations.