Joint Industry Paper on DNSH Guidance for the MFF 2028-2034
The European Commission has launched a concept paper on guidance for the “Do No Significant Harm” (DNSH) principle under the 2028-2034 Multiannual Financial Framework (MFF). The proposal aims to establish a simplified approach to applying DNSH across the whole EU budget, delivering greater legal certainty while reducing administrative burdens.
Our industry supports these objectives and the move towards a more harmonised application of DNSH. However, the current draft raises concerns about the treatment of fuels, technologies and energy infrastructure that remain essential for the transition to a climate-neutral energy system.
In response, a coalition of European energy industry associations has published a joint paper setting out our recommendations for achieving this goal.
Nine recommendations
- Revise the activity list to focus on activities posing a genuine environmental risk, so that emissions-reduction, efficiency and conversion projects can be assessed on their merits.
- Align DNSH with existing EU legislation on the environment, climate and energy, to avoid duplicative assessments.
- Justify decommissioning decisions for gas infrastructure, taking into account network planning, repurposing opportunities, future demand, CO₂ transport and energy security.
- Broaden the infrastructure repurposing carve-out to cover CO₂ transport, biomethane, hydrogen blending and gradual conversion to dedicated hydrogen networks.
- Introduce a transition-sensitive assessment that considers the availability, timing and feasibility of alternatives.
- Recognise natural gas, flexible and dispatchable generation, CHP and efficient district heating and cooling, along with CCUS, coal-to-gas, waste-to-energy and waste-heat recovery, where cleaner alternatives are not yet feasible.
- Stay open to different decarbonisation pathways, including renewable and low-carbon gaseous and liquid fuels, since full electrification is not feasible in every sector or region.
- Apply proportionate, simplified DNSH assessments to research, pilot, demonstration and first-of-a-kind projects, while keeping environmental safeguards.
- Explicitly recognise energy-security exemptions, covering supply disruptions, critical infrastructure resilience, diversification of supply routes and strategic production capacity, with clear and streamlined conditions.
Read our paper below.
