EEM NL Hub responds to the EU Taxonomy consultation
- jeroenheijnen
- Apr 13
- 4 min read
Updated: Apr 14
The Energy Efficient Mortgages NL Hub has reviewed the European Commission’s proposed amendments to the Climate Delegated Act and submitted a consolidated set of comments on behalf of its members. Our central message is clear: while the consultation aims to simplify the EU Taxonomy and make it more workable in practice, the current draft risks doing the opposite for residential mortgage lending.
Our analysis, prepared with input from the members and affiliated members of the EEM NL Hub, concludes that the proposed changes may reduce rather than increase the volume of EU Taxonomy-aligned residential mortgage loans. If implemented, we expect the new CDA wording to make compliance more difficult for new construction, post-2020 properties and residential renovation finance, with negative implications for Green Asset Ratios and the broader development of green funding markets.
At the same time, we do recognise a number of positive steps in the proposal. We welcome i) the addition of ’acquisition’ to activities 7.3 and 7.6, ii) the general intention to align the EU Taxonomy more closely with EPBD IV, and iii) the introduction of a deep renovation route under activity 7.7. However, in our view these improvements are too limited to solve the underlying usability problems with respect to residential property finance.
A core concern is that Section 7 still appears to be designed mainly from a corporate perspective, while residential homeowners are the actual counterparties in most mortgage lending transactions. The current framework insufficiently reflects how household lending works in practice, not only for the financing of new constructions in the Netherlands but also where loans finance multiple renovation measures at once, or where institutions must work with fractions of loans that cannot realistically be separated in funding and reporting.
We are also concerned about the timing mismatch between the EU Taxonomy and EPBD IV. The proposed shift from NZEB-based criteria to Zero-Emission Building requirements for new buildings is, in our view, premature. For residential properties, national implementation frameworks and data infrastructure will in many Member States not be operational before 2030. As currently drafted, this would create a period in which compliance becomes legally and technically unclear, especially for post-2020 buildings that would need to be assessed against new standards that are not yet fully available in practice.
The same issue arises for air-tightness testing and whole life-cycle GWP disclosure under activity 7.1. The draft wording lowers the air-tightness testing threshold and broadens its application, even though many Member States do not require such testing for residential buildings and the necessary evidence is often not available at building-unit level.
Likewise, the proposed GWP disclosure requirements go further than what is currently operational under EPBD IV for residential buildings, making compliance impossible in many cases until 2030 when GWP implementation will be required under EPBD IV.
For renovation, the EEM NL Hub remains concerned that the proposal does not introduce a genuinely workable new criterion for households. The current structure still relies too heavily on the concept of major renovation, strict primary energy demand calculations and fractional loan attribution, all of which are difficult to verify and operationalise in retail lending. We therefore argue for a more practical approach, including qualification routes linked to EPC improvement, Renovation Passports, National Building Renovation Plans and Minimum Energy Performance Standards under EPBD IV.
We also question the practical value of the newly proposed 60% primary energy demand reduction route in activity 7.7. Although the intention is positive, our assessment is that this threshold is so demanding that in many cases it will simply lead to the same outcome as the existing EPC A or top-15% routes. That means it may do little to expand the universe of green assets in practice, especially for properties that need staged renovation pathways rather than one deep renovation step.
Another major concern is DNSH. For residential lending, the proposed changes do not fundamentally resolve the problem that most DNSH criteria are impossible to assess at household or building-unit level. Public data sources do not contain the information needed to verify waste, pollution, biodiversity and similar criteria for individual properties. In our view, DNSH should be treated far more proportionately for residential mortgage lending, with greater reliance on national legal frameworks and public data sources where available.
In its response, the EEM NL Hub therefore calls on the European Commission to make the EU Taxonomy more coherent with national EPBD IV implementation, to provide interim solutions for the 2027–2029 period, to introduce workable renovation criteria for households, to clarify the treatment of post-2020 buildings and grandfathering, and to improve the process around interpretative Q&As and guidance.
Our position is not to weaken the EU Taxonomy, but to strengthen its real-world impact. If the framework is to channel capital at scale into the renovation and decarbonisation of Europe’s housing stock, it must be both ambitious and operational. An EU Taxonomy that cannot be applied in practice will not accelerate the market. A workable EU Taxonomy can.
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