We are pleased to contribute to this consultation seeking further input of a technical nature from relevant stakeholders. Our key messages are:
- We support the Commissions’ intention to put forward a legislative proposal for an EU GBS.
- EU GBS should be mandatory and introduced into the EU law through a regulation.
- Bonds issued in the EU should not be permitted to use the notion of an EU Green Bond unless they comply with the EU GBS.
- Key elements of the framework (e.g. use of proceeds) should be included in a prospectus to make it legally binding. A consideration should be given to putting forward a specific proposal for an EU GBS prospectus.
- EU green bonds should be forward-looking, financing new green assets and activities rather than re-finance the existing ones.
- Consider a mandatory verification of the environmental impact report.
More details in our full response (PDF)