Eurosif response to the Commission consultation on DNSH under the next MFF
As the EU prepares its next Multiannual Financial Framework (2028-2034), the future application of the "Do No Significant Harm" (DNSH) principle will play a key role in determining how public funding supports Europe's climate and environmental objectives.
For investors, a clear and credible DNSH framework is essential to ensure that public and private capital are directed towards the same transition objectives. By providing a common reference point across EU spending programmes, DNSH can strengthen policy coherence, support long-term investment decisions and help mobilise capital towards a resilient and competitive European economy.
Eurosif has responded to the European Commission's consultation on the concept note for the future application of DNSH under the next MFF, outlining investors' priorities for the future framework and the guidance that will underpin its implementation.
Eurosif’s key messages
Preserve DNSH as a robust safeguard for sustainable investment and public spending.
DNSH remains an important tool to ensure that EU funding supports the Union's climate and environmental objectives and avoids creating long-term environmental risks, lock-in effects or stranded assets.
Maintain a single, horizontal DNSH framework across the MFF.
A common approach across EU spending programmes can reduce complexity, increase legal certainty and streamline implementation for public authorities, beneficiaries and investors.
Ensure that exemptions and carve-outs remain targeted and proportionate.
While Eurosif supports the proposed list-based approach as a basis for simplification, broad exclusions and automatic exemptions could undermine the effectiveness and credibility of the framework.
In September 2026, Eurosif also published a position on the MFF, covering different aspects of the framework. Read the position here.
