Piet Hein Schram
17 nov 2025
Over the past weeks, EEM HUB NL has contributed to the European Commission’s consultation on the “Energy-efficient buildings – portfolio framework to increase lending for renovations (delegated act)”. In our response, we focused on questions 12–25, reflecting the perspective of Dutch mortgage lenders and other financial institutions.
Over the past weeks, EEM HUB NL has contributed to the European Commission’s consultation on the “Energy-efficient buildings – portfolio framework to increase lending for renovations (delegated act)”. In our response, we focused on questions 12–25, reflecting the perspective of Dutch mortgage lenders and other financial institutions.
Our input highlights, among others:
- The current limitations in data availability and quality (e.g. reliance on EPC/EP-Online and the lack of access to underlying and actual consumption data),
- The need for better governance and legal frameworks for data sharing, including GDPR-compatible solutions,
- The potential of proxy data and intelligent data infrastructures to enable scalable, auditable renovation finance,
- The importance of aligning the EU Taxonomy with EPBD IV to make “green” mortgage and renovation lending practically workable,
- Targeted measures to support worst-performing buildings and vulnerable households, combining guarantees, subsidies and standardised products, and
- The crucial role of one-stop-shops and independent advice in turning regulation into executable customer journeys.
With this contribution, EEM HUB NL aims to support a framework that is not only ambitious on climate, but also implementable for financial institutions and meaningful for homeowners across Europe.