Response to the call for evidence on the extension to the "Do No Significant Harm" principle under the next Multiannual Financial Framework.

This is ClientEarth's reply to the European Commission's call for evidence on the application of the “do no significant harm” (DNSH) principle to the Social Climate Fund and policy reflections for its future extension under the next Multiannual Financial Framework (MFF). Our contribution focuses on the future development of a single DNSH guidance for the next MFF. 

ClientEarth is generally in favour of a single DNSH guidance, as long as it becomes an effective safeguard against environmentally harmful public spending.

Here are our key recommendations:

• The guidance should act as a minimum requirement for EU funds, across all EU sectors. It should go beyond mere compliance with environmental law.
• The single guidance should clearly exclude harmful activities, such as for fossil fuels, from public funding. No measure or project can be automatically considered compliant with the DNSH principle
• We need to ensure the transparency, independence and objectivity of the assessments to make the DNSH guidance truly effective DNSH.