Daniel Gueguen

A need to reinforce the Alliance based on a medium-term strategy

On the exact day it was announced to be published, the EU Commission adopted its delegated act setting the technical screening criteria for climate adaptation and climate mitigation. Most issues raised were not taken into account or were pushed down the road. Nuclear energy, natural gas and agriculture as well as certain manufacturing activities will be dealt with in a complementary delegated act after summer.

The EU Commission continues to conceive the real economy as a virtual activity, some sort of game. Face with this situation, it is key to join forces and create a mass effect. Jointly signing position papers will not suffice; a transversal, massive advocacy campaign needs to be developed with a clear media angle.

Interested in joining forces for a fair taxonomy taking into account the views of the real economy?

Please contact

Daniel Guéguen daniel.gueguen@eppa.com LinkedIn +32 474 37 74 42

Vicky Marissen vicky.marissen@eppa.com LinkedIn +32 496 61 84 03

A short reminder of the next steps:

  • Potential veto of the delegated act on Technical Screening Criteria on the first two objectives of the Taxonomy (climate change mitigation & adaptation).
  • Technical Screening Criteria on the four remaining objectives (water and marine resources, circular economy, pollution prevention and control, biodiversity): to be adopted by the end of the year 2021.
  • ‘Complementary’ delegated act(s) for nuclear energy, natural gas, agriculture and certain manufacturing activities: post-summer 2021.
  • Company disclosures: by June 2021, the Commission will adopt a delegated act specifying the information companies subject to the Non-Financial Reporting Directive (2014/95) will have to disclose.
  • Renewed Sustainable Finance Strategy (June 2021), with new legislative proposals and policy initiatives related to capital markets, corporate finance and the banking sector.
  • Report on a possible ‘brown taxonomy’ (December 2021), with a focus on activities that significantly harm environmental sustainability and on transition activities, as well as a ‘social taxonomy’.

Methodology of work

It is our absolute intention to broaden and stabilize the Taxonomy Alliance, but its mission remains unchanged: creating a cross-sector platform that underpins sectoral action and advocacy on a transversal level under the motto: “Taxonomy: the economy is not a simulation game”.

The alliance by no means, wants to have a monopoly on representation on the Taxonomy dossier and replace bilateral actions. However, it does aim to:

  • Exchanging views, cross-cutting information related to the governance of this issue and the consistency or rather inconsistency of the taxonomy initiative in relation to the existing legislative framework in various sectors (energy, transport, agri-food, chemicals, etc.);
  • provide common services, in particular to optimize information flows;
  • and gain strong media visibility to counterbalance the NGO mobilization we are currently witnessing.

Sharing information and boosting the Alliance is a joint responsibility of all the organisations joining and will be the cornerstone of its success. The Alliance should stay an alliance, characterized by a light structure and be managed as a joint project. We suggest to create a small-scale Steering Group that could strategically further develop the Alliance and that would be able to attend meetings on behalf of the Alliance notably.

Priority actions

  1. Monitoring and intelligence-gathering
    One of the key missions of the Alliance is to track developments on taxonomy and sustainable finance. A monthly monitoring report is developed and circulated, gathering all relevant information.
    Monitoring will not be sufficient and further intelligence will be needed. We insist on the fact that this sharing of info and intelligence is a common responsibility of the members and only sharing info will make the actions of the Alliance relevant and on the ball.
  2. Procedure/strategy/argumentation
  • Support on the process in the context of the veto initially and afterwards for additional delegated acts, reviews of the taxonomy regulation and further initiatives on sustainable finance;
  • Development of a transversal argumentation to highlight concerns with regard to governance, coherence, transparency,… that can usefully be integrated in the argumentation of the members;
  • Definition of strategy and actions with regard to initially the veto period and afterwards additional delegated acts, reviews of the taxonomy regulation and further initiatives on sustainable finance.
  1. Advocacy & networks
  • Both in the short as well as medium turn, the Alliance will contact relevant MEP to brief them on the concerns related to taxonomy. This will also include contacts with certain political group advisors.
  • In parallel, contacts will be established at the level of the Permanent Representations in Brussels and the Council secretariat.
  • Also, at the level of the EU Commission, and notably beyond DG FISMA contacts will be further established both at service and cabinet level.
  • Stakeholders: after an exploratory contact with BEUC, a follow-up meeting has been accepted. Although not necessarily aligned on content, the organization sees a number of concerns with regard to governance. Common ground could be found there. Further outreach to other stakeholders will take place, in the context (and non-exhaustively) are on the radar: ETUC, Financial market players (European Banking Federation, the Association of Financial Markets in Europe,…)
  1. Communication
    In the short- and medium-term further mobilization via media will be organized to keep the topic and the concerns related to it, high on the agenda. This will notably consist of further articles and blogs, that can and should be relayed by the members.


Download the Taxonomy Alliance Action Plan 2021-2022

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