IOGP Europe’s input to the Commission’s draft guidance on the application of the ‘do no significant harm’ principle under the 2028-2034 Multiannual Financial Framework (MFF)

In this consultation response, IOGP Europe supports a simpler, more predictable and proportionate application of the Do No Significant Harm (DNSH) principle under the 2028–2034 Multiannual Financial Framework.  

IOGP Europe believes that certain sections of the draft guidance on the application of the ‘do no significant harm’ principle under the 2028-2034 MFF require refinement in order to provide greater clarity, reduce administrative burden and avoid blanket exclusion of technologies that would go against the principles of technology neutrality, industrial resilience and energy security for the EU. 

1. Avoid blanket exclusions: recognise credible transition pathways 

Applying a blanket exclusion to all fossil fuels disregards the reality that hard-to-abate industries will decarbonize progressively as technologies, infrastructures and competitive low-carbon energy becomes available. 

A rigid exclusion of investments associated with existing oil and gas activities could prevent financing for projects that materially reduce their environmental footprint (e.g. transitioning to lower-carbon intensity energy systems or the repurposing of energy infrastructure). 

2. Apply proportionality to actual environmental impact 

DNSH assessments should reflect the actual environmental risk, scale, purpose and characteristics of an investment, rather than rely primarily on project value or broad technology classifications.  

Compliance within existing EU frameworks, best available techniques (BAT), the EU ETS, the Industrial Emissions Directive and environmental permitting requirements should create a “presumption of compliance” with DNSH criteria, therefore avoiding duplicative documentation and parallel verification systems. 

3. Ensure industrial decarbonization thresholds are achievable 

The proposed 30-40% minimum GHG reduction threshold for certain industrial investments is too rigid and risks penalizing those whose remaining abatement potential is smaller, technically more complex or more expensive, such as:  

• Investments in first-of-a-kind or innovative technologies; 

• Necessary investments forming part of a wider, phased approach towards industrial decarbonization; 

• Industrial frontrunners that have already delivered substantial emission reductions. 

IOGP Europe recommends a 10-20% threshold alongside recognition of investments forming part of credible and time-bound decarbonisation pathways. 

4. Energy security and resilience must be part of DNSH implementation 

Environmental objectives should be implemented consistently with the EU’s wider priorities, including energy security, food security, industrial competitiveness and strategic autonomy.

The concepts of “crisis” and “overriding public interest” should therefore explicitly recognise energy-supply disruptions, critical energy infrastructure, diversification of supply routes and the need to maintain strategic industrial capacities. 

IOGP Europe therefore calls for a DNSH framework that is technology-neutral in its application and proportionate to environmental harm, for it to be capable of supporting credible transition pathways and of incentivizing measurable decarbonisation and transformation of energy systems.