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Cassa Depositi e Prestiti s.p.a.

CDP

Cassa Depositi e Prestiti is Italy's national promotional bank, supporting sustainable development, infrastructure, and business competitiveness since 1850.

Lobbying Activity

CDP urges EU to simplify Taxonomy and reduce reporting burdens

5 Dec 2025
Topic — The initiative reviews environmental delegated acts to update and simplify technical screening criteria.
Message — CDP recommends reducing indicators and introducing progressive targets with fewer documentation requirements. They suggest focusing DNSH requirements on material aspects for low-risk activities and introducing EU-wide harmonised templates. The group also proposes including technological modernisation for hard-to-abate sectors.123
Why — Streamlined requirements would reduce the bank's operational costs and facilitate public infrastructure funding.45
Impact — Environmental groups may fear that less stringent requirements risk enabling greenwashing in heavy industry.6
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Meeting with Michele Piergiovanni (Cabinet of President Ursula von der Leyen)

5 Nov 2025 · Introductory meeting to present CDP's activities

Meeting with Annalisa Corrado (Member of the European Parliament)

3 Nov 2025 · Taxonomy

Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

29 Jul 2025

Cassa Depositi e Prestiti S.p.A. (CDP) is Italys National Promotional Institution and the Italian Financial Institution for Development Cooperation, with total assets exceeding 470bn. CDPs mission is to promote economic development and strengthen capital markets by leveraging postal savings and debt capital. As Italys National Promotional Institution, CDP promotes indirect real estate development initiatives particularly in social housing, student housing, and senior housing through participation in real estate fund-of-funds managed by its subsidiary CDP Real Asset SGR S.p.A., which invests in target real estate funds. Both the funds-of-funds and the target funds operate under market conditions. Against this background, CDP supports the inclusion of a definition of affordable housing within the SGEI Decision. More broadly and beyond the scope of State Aid rules CDP believes that to effectively foster investment in social and affordable housing across Europe, the European Commission should provide a comprehensive EU-level definition of affordable housing applicable across all relevant policy areas. This EU-level approach would better support Member States in addressing housing needs at the national and local levels. To this end, CDP proposes the following definition of social and affordable housing, to be included in Article 2 of the SGEI Decision as well as in other relevant EU legislation. In addition to social housing, this definition would also include student housing, senior housing, and service housing linked to labour mobility. Such housing solutions would directly support, among others: low-income families, including single-parent or single-income; young low-income couples, elderly people in disadvantaged social or economic conditions, as well as non-resident students. Social and affordable housing refers to housing designed to address the needs of disadvantaged individuals and households who, due to market conditions, are unable to afford housing that meets minimum energy performance standards at prices proportionate to their income. Social and affordable housing may also include housing, available for sale or rent, intended for self-sufficient elderly individuals (senior housing), students (student housing), and workers requiring geographic mobility (service housing). CDP also proposes the following clarification to be included in Article 2 of the SGEI Decision. This addition would ensure that the scope of the Decision explicitly covers capital expenditures - such as construction and renovation - which are essential to delivering social and affordable housing services. In the field of social and affordable housing, this Decision shall also apply to State aid granted for the financing of the construction of new buildings and/or the renovation of existing buildings, as such investments constitute a substantial component of the overall costs for the provision of services of general economic interest aimed at addressing housing hardship, as defined above.
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Meeting with Stefano Signore (Acting Director Directorate-General for International Partnerships)

15 Jul 2025 · Financial support to coffee value chains in partner countries

CDP Urges Binding Copper Switch-off to Drive Fiber Investment

11 Jul 2025
Topic — Consultation on the Digital Networks Act to improve EU digital infrastructure investments.
Message — CDP recommends adopting a binding copper switch-off framework to drive a virtuous cycle of investment. They also suggest transitioning toward wholesale access over a single network to avoid infrastructure duplication.12
Why — Mandatory fiber migration would enhance investor confidence by improving long-term cash flow predictability.34
Impact — Legacy technology providers lose market share as outdated copper networks are systematically phased out.5
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Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

9 Jul 2025 · Shaping a new Team Europe approach towards LAC in order to increase the success rate of EU Railways industry on tenders on the region.

Meeting with Polyvios Eliofotou (Cabinet of Commissioner Costas Kadis)

7 Jul 2025 · Review of financial opportunities around the European Ocean Pact

Response to Proposal for an amendment to the InvestEU Regulation.

2 Jul 2025

Please find attached CDP's simplification proposals for the InvestEU Programme.
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Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Jul 2025 · Presentation of CDP work on corporate reporting simplification

Meeting with Jean-David Malo (Acting Director Research and Innovation) and Bpifrance

11 Jun 2025 · Future of the EIC and specificities of Italian stakeholders

Meeting with Maria Luís Albuquerque (Commissioner) and

4 Jun 2025 · CSRD and Access to Capital Makerts

Response to European Affordable Housing Plan

3 Jun 2025

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution, with total assets above 450bn. CDP aims to promote economic development and foster capital markets by leveraging postal savings and debt capital. CDP also supports public administrations in managing financial resources efficiently. CDP Group has been financing solutions for social housing since 2010 in partnership with CDPs minority shareholders, i.e. banking foundations. At present, through a dedicated asset and fund management subsidiary (CDP Real Asset SGR), CDP Group promotes the development of social housing infrastructure in Italy with a focus on fostering sustainability, urban regeneration, and social cohesion. In this light, CDP welcomes the upcoming European Affordable Housing Plan as an important step towards addressing the housing crisis in the EU by unlocking public and private investment and bridging the existing funding gap in the sector. With the aim of illustrating the role that National Promotional Banks and Institutions (NPBIs) can play in identifying and implementing policy priorities in the field of affordable housing, we attach CDPs position paper on housing (Promoting Long-Term Investment in Affordable Social Housing in Europe: The Role of National Promotional Banks and Institutions, March 2025), which: i) presents CDP Groups affordable social housing investment model as a successful example of how NPBIs can effectively promote growth and development of affordable social housing; and ii) provides policy recommendations to shape upcoming EU initiatives in the field. In addition, we also recommend consulting the ELTI-EAPB brochure on housing (Addressing the Housing Crisis. The Contribution of National Promotional Banks and Institutions in Europe, April 2025), which presents a variety of projects in different Member States, showcasing how NPBIs have addressed specific needs and established tailored support structures. This can be accessed at the following link: https://www.flipsnack.com/eltia/elti-brochure-9-housing/full-view.html
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Meeting with Antonella Sberna (Member of the European Parliament)

3 Jun 2025 · Strumenti finanziari per la competitività, coesione dell’Unione Europea, investimenti strategici per l’autonomia economica e lo sviluppo dei territori.

CDP urges simplified sustainable finance rules for startups and VC

30 May 2025
Topic — The consultation reviews EU sustainable finance disclosure rules to simplify frameworks and prevent greenwashing.
Message — CDP proposes a new category for financial instruments supporting sustainable innovation. They suggest simplified reporting for venture capital based on estimated performance indicators. The group calls for better alignment between various EU sustainability regulations.123
Why — This would lower administrative burdens and help their funds achieve sustainability labels.4
Impact — Investors may receive less standardized or verifiable data compared to larger corporate disclosures.5
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Meeting with Elena Martines (Cabinet of Commissioner Ekaterina Zaharieva)

15 May 2025 · Italian NPB, the CEO changed in April. Their financial strategy is highly diversified, they are a partner in Invest EU and one of the 5 main EU NPBs with KfW,BGK, BPI France and ICO Spain, part of the group managed by the EIB (“5+1”).

Italian lender CDP urges EU to de-risk nuclear investments

9 May 2025
Topic — The Commission is mapping investment needs across the European nuclear energy ecosystem.
Message — CDP proposes an EU-backed facility to combine public grants with long-term loans for nuclear projects. They also advocate for harmonised licensing frameworks to simplify international cooperation on next-generation reactors.12
Why — EU funding and guarantees would reduce the financial risks for CDP's nuclear subsidiaries.34
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Meeting with Valdis Dombrovskis (Commissioner) and

15 Apr 2025 · Omnibus

Meeting with Raffaele Fitto (Executive Vice-President) and

15 Apr 2025 · Cassa Depositi e Prestiti initiatives and priorities

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

15 Apr 2025 · Courtesy meeting

Response to Interim evaluation of the Strategic Technologies for Europe Platform (2024-2025)

9 Apr 2025

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution, with total assets exceeding 450bn. CDP is a long-standing partner of the European Commission (EC) in supporting the management and deployment of EU resources. CDP is Implementing Partner (IP) of the InvestEU Programme and the CEF Transport Alternative Fuels Infrastructure Facility. CDP is also supporting the implementation of 16 National Recovery and Resilience Plan (NRRP) projects and providing technical assistance to public administrations to monitor NRRP implementation. CDP welcomed the adoption of the STEP Regulation as part of the of the mid-term revision of the long-term EU budget and as a first response to support investments in critical technologies in the EU. STEP has been an effective tool to reorient Cohesion Policy funds priorities to new and urgent investment needs. Within the EU, a total of 6.2bn funds have been reprogrammed towards STEP objectives. In Italy, 10 operational programmes (9 regional and 1 national) have reprogrammed cohesion policy resources towards STEP objectives, amounting ~3bn, i.e. 48% of the current STEP allocation at EU level. In this context, CDP is taking on an increasingly significant role, being accredited by the Department for Cohesion and Southern Policies of the Italian Presidency of the Council of Ministers (PCM) to support the STEP implementation. In particular, CDP will support the PCM (in its capacity of National Contact Point STEP in Italy) and the Managing Authorities upon request by the PCM to: 1. Coordinate and monitor activities, as well as to screen projects submitted to STEP Calls for Expression of Interest; 2. Structure financial instruments to attract co-investments with STEP resources; and 3. Assist project promoters in securing additional financing for projects awarded the EU STEP Seal. Areas for improvement In Italy, State Aid rules are a significant barrier to the implementation of STEP, especially for those regions that do not qualify for State Aid under Article 107, paragraph 3c of the Treaty on the Functioning of the European Union. As a result, some regions that have reprogrammed cohesion policy resources towards STEP objectives face difficulties to allocate such funds, due to State Aid restrictions. This issue is particularly relevant for project prioritising industrialisation over research and development (R&D), as R&D projects could qualify for State Aid under the GBER Regulation. Therefore, it is important to revise and ease State Aid restrictions for STEP projects to facilitate their implementation. In addition, the European Commission should arrange workshops and promote knowledge sharing on STEP and relevant strategic technologies. This would improve understanding and ensure effective implementation by the Managing Authorities. Given CDP's role in helping project promoters secure additional financing for STEP Seal-awarded projects and as an InvestEU Implementing Partner, it is also recommended that both the Commission and the InvestEU Investment Committee consider the Seal when assessing STEP projects, thus ensuring a simplified approval procedure, reducing information requirements and assessment time. Specific suggestions may include: 1. Exempting CDP from compiling the policy related sections of the Policy Check Request Form, as the STEP Seal confirms that the project is aligned with EU policy priorities 2. Simplifying information requirements regarding environmental sustainability analyses (e.g. Sustainability Proofing Summary), as compliance with EU environmental and sustainability rules was already assessed when the STEP Seal was awarded. Overall, CDP believes that the STEP model could be further utilised in the future to introduce flexibility in Cohesion Policy funds and support the most strategic sectors of the EU economy. Some adjustments, however, are needed to ensure effective execution of STEP projects.
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Meeting with Carla Montesi (Director Directorate-General for International Partnerships)

27 Mar 2025 · • Finalisation of the TERRA guarantee agreement • Potential collaboration on digital infrastructure

Meeting with Piotr Serafin (Commissioner) and

27 Mar 2025 · Exchange of views on the future Multiannual Financial Framework and other EU priorities

Meeting with Jozef Síkela (Commissioner) and

24 Mar 2025 · Global Gateway

Cassa Depositi e Prestiti seeks simpler green asset reporting

19 Mar 2025
Topic — This initiative updates EU taxonomy rules to simplify sustainability reporting for companies.
Message — CDP requests the exclusion of local governments from green asset calculations as they lack the capacity to verify environmental alignment. They also want reporting perimeters aligned with national laws to ensure consistency across financial disclosures.12
Why — This change prevents the organization's green performance scores from being unfairly lowered by local government loans.3
Impact — Investors and environmental groups lose standardized data regarding the green impact of public sector funding.4
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Response to EU Start-up and Scale-up Strategy

14 Mar 2025

Cassa Depositi e Prestiti (CDP) is Italy's National Promotional Institution. CDP Venture Capital is the VC arm of the CDP Group, managing ~5bn in assets. CDP VC is part of the European Venture Fund Investors Network (EVFIN), a group of 23 national VC and private equity operators from 21 European countries. EVFIN members propose 8 recommendations to support EU startups and scaleups: 1. Fostering technology transfer (TT). EVFIN members support TT to turn Europe's research excellence into deep-tech innovation. The EU should promote TT initiatives across Member States, focusing on universities, research centres and start-up collaboration, as well as improving efficiency and professionalising TT. Boosting pre-seed, seed, and early-stage funding is also crucial. 2. Encouraging collaboration between startups and SMEs. EU-led venture-building initiatives could establish new ventures that offer innovative products/services to SMEs. The EU could create a pan-European digital platform with physical hubs, connecting startups, SMEs, and corporates to drive products/services exchange, digitisation, and growth. 3. Enhancing corporate participation in VC. Corporates engaging in VC gain access to innovative technologies, boosting their competitiveness. This also helps startups by fostering growth and exit opportunities. The EU should launch a programme backing corporate VC (CVC) funds in key sectors and promoting corporate investment, engagement, and mentorship. The EU SME definition should be revised to enhance CVC investments. 4. Retaining unicorns and decacorns in Europe. The EU must enhance its listed tech segment. National VC operators and the EIF should strengthen crossover funds with cornerstone investors to support listings. More tech-buyout funds should be created to support later-stage fundraising and increase liquidity. EU VC funds should pivot towards deep-tech startups. EU funding programmes must also back capital-intensive ventures. 5. Facilitating institutional investor participation in VC. The EU should mitigate risk for institutional investors in VC and adjust rules to allow pension funds and insurers to take long-term VC risks and prioritise returns. National tax authorities could level the playing field for all VC investors and provide incentives. Additionally, the EIF and EVFIN members could: i) guide institutional investors in assessing VC funds; ii) anchor private VC fund-of-funds to attract institutional capital; iii) spur retail VC investment. 6. Revising the EU State aid framework for fundraising. The EIB, FEI and NPIs are not independent private investors under EU State aid rules. This restricts their investments into VC funds and role as anchor investors, consequently State aid rules should be updated to recognise them as private investors when operating at market terms. In addition, the 30% private investors threshold should be reduced and/or delayed to later investments round stages in startups (from round B). 7. Strengthening the Capital Markets Union (CMU) and the Single Market. Completing the CMU will increase cross-border capital flows, facilitating innovation funding and improving startup financing. Pan-European funds and investment products should be fostered. A 'competitiveness check' should be applied to EU rules, ensuring a level playing field with non-EU financial players. A stronger Single Market, particularly in the digital field, is key for startups to grow. Streamlining and digitising public procurement will boost demand. Improving IP protection is also essential to drive innovation. 8. Simplifying and harmonising EU rules. The EU should avoid over-regulating innovative sectors and foster a more agile regulatory environment. EU rules should be assessed for innovation impact, barriers removed, and innovation fostered (applying the innovation principle). A 28th regime for innovative firms, clearer sustainability rules, and further EU acquis harmonisation would help start-ups thrive in Europe.
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Response to Savings and Investments Union

4 Mar 2025

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution, with total assets above 450bn. CDP aims to promote economic development and foster capital markets by leveraging postal savings and debt capital. CDP also supports public administrations in managing financial resources efficiently. The EU strategy to develop the Saving and Investment Union (SIU) aims to support family wealth creation by increasing returns on citizens' savings and expanding business financing opportunities. This strategy involves both capital markets and the banking sector, requiring regulatory interventions to enhance market efficiency. Indeed, current regulations, layered between the EU and national levels, complicate cross-border activities and discourage foreign operators. Greater regulatory, tax, and supervisory integration is crucial to overcome these differences and create a true SIU. Proposals such as the 28th tax regime can move in this direction. It is also important to include the integration of banking markets, as banks are crucial for financing SMEs. A case in point is the lack of a European deposit insurance. Key factors affecting the Italian capital market include: Use of Market-Based Financing: Italy ranks below the European average in market funding ratio (38% vs European average 49.8%), heavily relying on debt instruments and bank channel. Capital supply: low presence of institutional investors in business financing, especially in equity segments. In Europe, the participation of such investors is significantly lower than in the U.S. As of November 2024, the market capitalisation of the top 100 U.S. companies attributable to institutional investors was around 74%, compared to 42% for the top 100 European companies. Liquidity: There is a low volume of stock trading, especially for smaller companies. Only 10% of the stocks listed on Euronext Growth Milan in 2024 had a daily trading volume exceeding 100,000 euros. Productive Structure: Structural growth rates are lower compared to other European peers, with a higher proportion of micro-enterprises (0-9 employees) making up 94% of the production system. These factors contribute to the limited development of the Italian capital market, impacting non-bank financing for businesses, growth, investment, and innovation capacities, particularly for SMEs. For this reason, CDP contributes to capital market development through various activities. For instance, CDP Group plays a primary role in developing private capital markets such as Private Equity and Venture Capital (VC), supporting business financing across all phases and collaborating with universities and research centres. Recent initiatives include 20 acceleration programmes and 5 technology transfer hubs, selecting 250 startups for acceleration. In VC, CDP Group has launched new funds targeting innovative sectors like aerospace, biotechnology, low-emission production technologies, and AI applications. In 2024, CDP Venture Capital SGR, the VC arm of CDP Group, was one of the most active investors financing Italian startups. To increase trading volumes in public equity for SMEs, CDP also launched the Indirect National Strategic Fund to invest in listed SMEs. Furthermore, CDP supports Private Debt market development with dedicated Diversified Debt Funds and investments in other operators' funds. Moreover, it has advanced innovative debt instruments, including social bonds, green bonds, and basket bonds for SMEs. Notably, CDP issued Italy's first Digital Bond on blockchain (1.25 billion in Feb 2025). In addition, CDP launched several financial education initiatives, involving students from different age groups, with the aim of increasing the awareness regarding investment opportunities and risks.
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Italian lender CDP urges massive EU water infrastructure investment

3 Mar 2025
Topic — The EU's plan to achieve water resilience and manage scarce resources across Europe.
Message — CDP calls for modernizing aging infrastructure and strengthening interconnections between major water systems to prevent shortages. They advocate for reducing network losses and expanding the reuse of treated wastewater.12
Why — The strategy supports CDP’s strategic goal to scale up its water investment portfolio.3
Impact — Small, fragmented local operators may struggle to meet new investment and efficiency standards.4
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Meeting with Andrius Kubilius (Commissioner) and

25 Feb 2025 · Financial sector on defence, investment policies, EU regulatory framework

Meeting with Marco La Marca (Cabinet of Commissioner Dubravka Šuica)

20 Feb 2025 · Cooperation development in the Mediterranean.

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto)

19 Feb 2025 · Presentation of CDP activities

Meeting with Matthew Baldwin (Deputy Director-General Energy)

13 Feb 2025 · Exchange of views on housing policy and investments by CDP

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

13 Feb 2025 · Exchange of views on housing policy and investments by CDP

CDP urges full single market integration to boost European competitiveness

28 Jan 2025
Topic — The European Commission is developing a strategy to improve the internal single market.
Message — CDP calls for the full realization of the four fundamental freedoms. They advocate for a Banking Union to support startup growth. They request coordinated financial efforts for the green transition.12
Why — Better market integration would help CDP fund Italian businesses and infrastructure projects more effectively.3
Impact — High-debt nations lose competitiveness as wealthier neighbors provide significantly more national state aid.4
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Meeting with Antonella Sberna (Member of the European Parliament)

3 Dec 2024 · Finanziamenti per le startup e il ruolo dell’IA: opportunità e strategie per le imprese italiane

Meeting with Marc Lemaitre (Director-General Research and Innovation)

3 Dec 2024 · EIC Accelerator

Cassa Depositi e Prestiti supports EU energy renovation framework

4 Nov 2024
Topic — The Commission is developing a voluntary framework to increase bank lending for energy-efficient building renovations.
Message — CDP recommends a framework featuring tailored products like green mortgages and energy efficiency loans. It calls for project selection based on energy savings and cost-effectiveness to ensure financial viability.123
Why — The framework helps CDP align its large-scale investments with EU sustainability and energy targets.4
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

15 Oct 2024 · Digital matters

Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

20 Sept 2024

CDP is the Italian National Promotional Institution (NPI) and one of the largest Italian financial institutions, with total assets above 450bn. The experience of CDP with CEF1 Programme was mainly linked to the implementation of the CEF Transport Blending Facility launched in 2019, which supported the deployment of alternative fuel supply infrastructures and of European Rail Traffic Management Systems (ERTMS) along the TEN-T Network through blending operations (EU grants combined with support from financial institutions). In March 2020, CDP signed an Administrative Agreement with the European Commission (EC) to implement the facility, becoming the only Italian Implementing Partner (IP) of the initiative. CDP supported four Italian promoters during the 3rd, 4th and 5th cut-off dates (the last one on 15th March 2021), with three of these projects receiving a total of 8.5mln in EU grants. Based on CDPs experience, the CEF Transport Blending Facility has fully met the general and specific objectives of CEF1, by accelerating investments in trans-European transport networks and delivering added value that would have been difficult to achieve for the private sector or Member States alone. As the Italian IP, CDP: i) identified new projects relevant to AFIF; ii) performed due diligence on such projects, which was shared with the EC; iii) co-financed projects, covering at least 10% of the total costs. The effectiveness of the CEF Transport Blending Facility is mainly due to the IPs catalytic role and the streamlined application and selection process (for further details, please see CDP response to Call for evidence Connecting Europe Facility 2021-2027 interim evaluation). It is worth highlighting the crucial role played by blending instruments and the role of IPs in CEF1: according to the data of the Italian Ministry of Transport, during the 2014-2020 CEF1 programming period, 28 sustainable mobility projects with Italian beneficiaries were financed, with 13 receiving funding through the 2017-2018 blending calls and the Blending Facility launched in 2019. This successful experience led to the establishment of the Alternative Fuels Infrastructure Facility (AFIF) under CEF2 Transport. AFIF calls for 2021-2023 and 2024-2025 under CEF2 confirmed the crucial role of blending EU grants with financial support from NPIs to deploy alternative fuels infrastructures. This approach has effectively addressed market failures and catalysed significant investment in green mobility. However, DG MOVE anticipated that the current call 2024-2025 will be the last AFIF call under CEF2, as the budget allocated to this facility is running out. In this respect, CDP strongly calls for an extension of AFIF beyond 2025, ensuring enough budget until the end of the current MFF (e.g., by reallocating unused EU budget). Furthermore, CDP advocates for a new transport blending facility in the next MFF, based on the successful AFIF model, which would allow the EC to leverage financing for alternative fuels projects, building on a trusted network of IPs. Finally, CDP reiterates the importance of introducing AFIF-like instruments for CEF Digital and Energy. These two sectors will require major investment to achieve the EU green and digital objectives. NPIs can, therefore, play a crucial role to make the most of the EU budget, leverage available resources, and attract additional private and public investments.
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Response to Interim evaluation of the Connecting Europe Facility 2021-2027

20 Sept 2024

CDP is the Italian National Promotional Institution (NPI) and one of the largest Italian financial institutions, with total assets above 450bn. So far, CDP experience with CEF2 Programme has been mainly linked to the implementation of the Alternative Fuels Infrastructure Facility (AFIF) under CEF Transport. In April 2022, CDP signed an Administrative Agreement with the European Commission (EC) to implement AFIF for the period 2021-2023, which followed up a similar agreement under CEF1 and confirmed CDPs role as the Implementing Partner (IP) of CEF Transport in Italy. As the Italian IP, CDP: i) identifies new projects relevant to AFIF; ii) performs due diligence on such projects, which is shared with the EC; iii) co-finances projects, by covering at least 10% of the total costs. Based on CDPs experience, AFIF has fully met the general and specific objectives of CEF2, by accelerating investments in trans-European transport networks and delivering added value that would have been difficult to achieve by the private sector or Member States alone. AFIF generates many benefits: The facility systematically crowds-in public and private investors. Not only IPs finance a minimum share of the project value, but they often provide debt financing in pool with commercial banks, catalysing additional private money. IPs due diligence brings financial discipline and technical maturity, ensuring that projects selected are completed on time and deliver the expected results. The instrument is lean, simple and allows applicants to access funding in a short timeframe. IPs help project promoters prepare their applications and can liaise with the EC to address project-specific issues before submission. NPIs are best placed to promote the instrument at national level due to their knowledge of local needs and their coverage teams actively searching for new projects to support. This generates a strong pipeline of eligible projects, which are technically and financially sound. CDPs success is evident: in the 2021-2023 AFIF call, eight projects (including two big multi-country projects) supported by CDP were awarded around 225mln in EU grants. These projects will lead to the installation of almost 11000 charging points in several Member States and the electrification of ground operations in two airports. CDP has been a key player, securing one of the highest amount of EU grants and among the first institutions to contribute to the electrification of airports. 1/3 of the successful proposals submitted overall by Italian applicants in the 2021-2023 call were supported by CDP, with an approach that has evolved over time to include smaller but innovative and value-adding projects. AFIF projects have nearly exhausted the TEN-T eligibility map for electric charging stations, contributing to the massification of recharging infrastructure. The third AFIF call (2024-2025) is once again proving the success and the effectiveness of the instrument in spending the allocated EU budget. In particular, in Italy CDP is experiencing a growing interest also for the other eligibility areas of AFIF, such as the greening of port operations and the deployment of green hydrogen mobility infrastructures. Against this background, CDP strongly calls for an extension of AFIF beyond 2025, ensuring enough budget until the end of the current MFF (e.g., by reallocating unused EU budget). In addition, CDP advocates for a new transport blending facility in the next MFF based on the well-established AFIF model, to leverage financing for alternative fuels projects by building on a trusted network of IPs. Finally, CDP reiterates the importance of introducing AFIF-like instruments in CEF Digital and CEF Energy. These two sectors will require major investment to achieve the EU green and digital objectives. NPIs can, therefore, play a crucial role to make the most of the EU budget, leverage available resources, and attract additional private and public investments.
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Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

CDP is the Italian National Promotional Institution (NPI) and one of the largest Italian financial institutions. CDP fosters sustainable development in Italy, promoting growth and employment, innovation, business competitiveness, infrastructure, and local development. As an Implementing Partner (IP) of InvestEU, a financial institution disclosing information according to the EU Taxonomy, and an Observer in the Platform on Sustainable Finance, CDP welcomes the application of the DNSH principle to the Social Climate Fund (SCF) and the development of policy reflections for its extension under the next MFF. To promote a more effective, coherent, and streamlined application of the DNSH principle that enhances synergies across EU funding instruments and minimises administrative and compliance costs, CDP proposes the recommendations below. CDP stands also ready to establish a committee involving NPIs to advise EU institutions on the DNSH principle. SOCIAL CLIMATE FUND Different DNSH guidelines applying to different EU programmes, on top of the EU Taxonomy criteria, may create overlaps and duplications. Therefore, as regards the SCF, CDP advises ensuring: i) alignment between SCF DNSH Technical Guidance and the technical criteria and application measures already contained in the existing EU Taxonomy regulations for the same type of investments (e.g., construction of new buildings, renovation of existing buildings); and ii) enough flexibility to account for equivalent rules that are already in force in EU Member States to support EU funded projects (e.g., technical criteria for DNSH verification defined in Italy for the construction or renovation of buildings in the National Resilience and Recovery Plan). This would allow harmonising assessment criteria at EU level and making them technical standards of reference. OTHER EU PROGRAMMES The DNSH principle was developed before the pandemic and the energy crisis. During the crises we learnt that the DNSH may lead to excessive projects exclusion and make it difficult to respond to emergency situations. In addition, performing a DNSH assessment may be time consuming and costly for both funding entities and beneficiaries. In this context, CDP advises adopting a two-pronged approach to enforcing the DNSH principle. For non-repayable instruments under direct management (e.g., CEF, Horizon Europe), the European Commission (EC) should be able to enforce the principles application as it considers fit. By contrast, for repayable instruments under indirect management (e.g., InvestEU), continuity with current practices should be ensured (e.g., sustainability proofing), so that such instruments are affordable and generate benefits higher than costs. For projects funded by blended instruments, combining repayable and non-repayable funding, one set of rules (ideally those for repayable instruments) should apply, thus avoiding duplications. In addition, the EC should consider relying on relevant policies and procedures of all IPs, not limited to the EIB Group and EBRD. An ex-ante evaluation of the IPs policies and procedures could be carried out at entity level, as opposed to evaluating each of the IPs operations, thus simplifying the process. Should the DNSH principle apply at the project level, projects below 10mln should be exempted, as it is already the case under InvestEU. CDP also calls for a differentiation based on programmes or financial products policy objectives, whereby the DNSH principle should be part of the policy impact analysis of green-focused initiatives, while its application should not hamper initiatives with other policy goals (e.g., competitiveness, social inclusion). Finally, based on CDPs experience under InvestEU, in cases where documentation demonstrating compliance with the DNSH principle is unavailable, accepting a self-declaration from the beneficiary would ensure that projects are not excluded as non-compliant solely due to the absence of relevant documents.
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Meeting with Stephanie Riso (Director-General Budget)

15 May 2024 · Presenting the EU issuance programme and discussing opportunities for investors to invest in EU bonds.

Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

Governments can increase investor confidence in engaging with energy efficiency markets by providing stable financial support that is not subject to frequent changes or uncertainties. Capital grants offer unique advantages in terms of upfront cost coverage, risk reduction, innovation incentives, equity considerations, market transformation, and long-term benefits. However, capital grants typically fund only portions of energy efficiency projects. While grants alone mitigate some investment risks for private investors, they frequently fail to render the business model attractive to private entities. Providing long-term capital grants tailored to specific energy efficiency interventions is imperative for strengthening investor assurance and unlocking private investments. There is also a need for an effective combination mechanism involving grants and loans (with low interest rates tied to specific energy performance criteria) backed by public financial institutions, and to provide business and individuals access to credit assignments to leverage available incentives. Lending institutions should identify energy efficiency projects as priority and act accordingly with their funding strategies. The combination of grants and loans plays a pivotal role in bridging the gap between the public and private sectors, facilitating the implementation of energy efficiency renovations by coordinating public authorities, private operators (e.g., ESCOs), and financial entities (e.g., financial intermediaries and other investors). In addition to financing solutions, mobilizing significant private financing for energy efficiency should be supported by advisory services and technical assistance at all levels (e.g., awareness raising, project scouting, project deployment, decision-making processes, reporting, monitoring, etc.). Several barriers to private investment in energy efficiency stem from financial issues (e.g., lack of dedicated and affordable financing solutions, long payback periods for energy efficiency renovations, etc.). However, non-financial issues are also significant bottlenecks (e.g., lack of skills to plan and execute proper renovations, difficulties in decision-making processes, lack of awareness, etc.), especially for complex projects like energy efficiency renovations of public buildings and public lighting. Therefore, advisory support and technical assistance (technical, financial, economic, legal), particularly for public entities, are crucial for preparing projects, procedures, and monitoring systems. These types of projects often take several years to implement; hence, it is vital to initiate preparatory activities as soon as possible and ensure continuity over time. Public authorities need support in organizing and processing data related to energy efficiency investments as they typically lack the necessary energy consumption data and information to judge the technical and economic foundation of an EE project. Moreover, tailored support can be provided according to the financing solutions (e.g., Public-Private Partnerships, Energy Performance Contracts), such as evaluating the EPC to maximize the impact of the energy efficiency project, reduce its perceived complexity, and ensure profitability for the provider, thereby creating a win-win scenario (sharing benefits between public and private parties, while also considering the sharp increase in public debt levels). The combination of (long-term) grants and loans (supported by interest subsidies), along with coordinated advisory support and technical assistance, generates economies of scale and promotes a one-stop-shop approach.
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Meeting with Koen Doens (Director-General Directorate-General for International Partnerships)

26 Feb 2024 · Global Green Bond Initiative

Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Confrontando il regime comunitario con le disposizioni nazionali, le aree di accelerazione, dalla definizione di cui alla Direttiva RED III, sembrano rappresentare le c.d. aree idonee della legislazione italiana. Nelle aree idonee italiane, sotto rilascio delle relative autorizzazioni da parte delle Autorità Competenti, possono essere installati e realizzati Impianti FER in adempimento al PNIEC (Piano Nazionale Integrato per l'Energia e il Clima). Inizialmente, i criteri di individuazione delle aree idonee erano normati dal DM 10/09/2010, che indicava alle Regioni e alle Province Autonome le modalità per lindividuazione di aree idonee (ed inidonee). Molte regioni sono intervenute sia a livello legislativo che pianificatorio (ad es. con i PER - Piani Energetici Regionali). Lart. 20 D.lgs. 199/2021 (attuazione Direttiva RED II) conferisce al Ministero dellAmbiente lattuazione di uno o più decreti per lindividuazione di aree idonee per linstallazione FER da adottare entro 180 giorni dalla data di entrata in vigore del decreto stesso. Entro ulteriori 180 giorni, le Regioni, con propria legge, avrebbero dovuto individuare le già menzionate aree idonee. Lart. 20 D.lgs. 199/2021 è entrato in vigore il 22/04/2023. Decorso il termine di 180 giorni, il Ministero dellAmbiente ancora non ha adottato alcun DM che sostituisca quello del 10/09/2010. Ad ogni modo, le norme più recenti (artt. 20 e seguenti del D.lgs. 199/2021 come s.m.i., art. 12 D.L. 17/2022, art. 7- sexies D.L. 21/2022 e art. 6 D.L. 50/2022) hanno individuato delle zone territoriali nelle quali applicare una forte semplificazione delliter autorizzativo degli impianti FER proponendo la deroga alla VIA (Valutazione di Impatto Ambientale). Il 13/07/2023 il Ministero dellAmbiente ha consegnato lo schema di decreto per lindividuazione delle aree idonee in Conferenza Unificata delle Regioni, in aggiornamento al DM 10/09/2010. Di fatto, il decreto individua la ripartizione fra le Regioni e le Province autonome di installazione FER per raggiungimento dellobiettivo nazionale al 2030 e stabilisce criteri omogenei per lindividuazione delle superfici e delle aree idonee e non idonee funzionali al raggiungimento dei suddetti obiettivi. Lo schema di DM, tuttavia, non identifica le aree idonee e questa competenza rimarrebbe in capo alle Regioni e alle Province Autonome che dovranno esprimersi a valle dellapprovazione dello stesso decreto. Le Regioni e le Province Autonome, quindi, dovranno identificare le aree idonee e definire gli strumenti di pianificazione (es. piani provinciali o regionali) per legittimare linstallazione degli impianti FER in tali aree e tali strumenti saranno da sottoporre a procedura di VAS (Valutazione Ambientale Strategica) per consentire la deroga alla VIA caso per caso. Ne potrebbe derivare un quadro finale estremamente frammentato sia a livello geografico che a livello temporale. In considerazione delle stringenti tempistiche di attuazione degli obiettivi del 2030, si ritiene opportuno che siano messi in campo dei meccanismi incentivanti per velocizzare lidentificazione delle aree idonee (o aree di accelerazione) da parte delle Regioni e delle Province Autonome. In subordine, per superare limpasse della regolamentazione delle aree idonee da parte delle Regioni e delle Province Autonome, si suggerisce che lownership della identificazione delle aree idonee debba essere in capo agli Stati Membri, sottoponendo solo alla fine la selezione di tali aree al vaglio finale delle Regioni e delle Province autonome. Tale selezione di aree dovrà quindi essere inserita in un documento di pianificazione nazionale da sottoporre al necessario percorso di VAS al fine di permettere la deroga alliter di VIA caso per caso. Gli Stati Membri potranno essere aiutati da Commissioni e/o enti terzi, eventualmente istituiti allo scopo, per affiancamento tecnico nellidentificazione delle aree, anche attraverso idonei strumenti di vaglio e valutazione.
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Response to Interim Evaluation of the European Defence Fund

20 Feb 2024

Building on our positive experience of the CEF Transport Alternative Fuels Infrastructure Facility (AFIF), to foster the competitiveness, efficiency and innovation capacity of the European defence technological base throughout the EU, a blending facility combining EU grants with debt financing from national financial institutions would contribute to improving access to finance for the defence sector by catalysing additional private and public investments. The AFIF governance, which could be replicated also in the defence industry, is structured as follows: - Promoters: The organisations that apply for a CEF AFIF grant. - Implementing partners (IPs): National Promotional Banks and Institutions or Multilateral Financial Institutions that are signatories of an Administrative Agreement with DG MOVE to implement the AFIF at the national or EU level. - Non-implementing partners (NON-IPs): other public or private financial institutions established in the EU. IPs can contribute to create sound and bankable pipelines for investments in defence, carrying out the following activities: - Initial screening of project proposals. - Project pre-evaluation and assessment of the technical and financial capacity of proponents (due diligence activities). - Drafting a financial approval letter, including the commitment to co-finance the investment project. In the case of AFIF, the IPs are committed to finance at least 10% of the overall costs of the projects with a loan, with the possibility to crowd-in additional private investments, leveraging on commercial banks. Besides the grants provided by the European Union, the main benefits of AFIFs approach to blended finance include: - Reduction of administrative burdens: - - The instrument is lean, simple and allows applicants to access funding in a short timeframe. - - Promoters interact with the IP by asking questions and clarification before submitting their application. - - IP can liaise with the Commission to address project-specific issues ahead of the submission deadline. - Improvement in projects technical and financial quality, thanks to IPs screening and due diligence. - Leverage of EU funds to crowd in additional public and private investors. - Creation of a strong project pipeline that is co-financed by both EUs and IPs funds, encouraging the financial participation of other economic operators. - Creation of synergies with other EU programmes (e.g., InvestEU Advisory Hub resources to prepare technical and financial documentation of projects).
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

5 Feb 2024 · EU Sustainable Finance

Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton)

31 Jan 2024 · Preparatory meeting in view of meeting between Commissioner Breton and CDP CEO

Italian lender CDP urges 25% cut in InvestEU reporting

1 Dec 2023
Topic — An initiative aiming to reduce EU legislative reporting requirements by 25 percent.
Message — CDP requests reducing InvestEU reports and data entries by at least 25 percent. They also propose simplifying sustainability proofing for social infrastructure to lower costs.12
Why — This would lower administrative expenses and accelerate the deployment of financial instruments.3
Impact — Regulators may lose oversight of project impacts if sustainability and risk reporting are reduced.4
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Meeting with Patrizia Toia (Member of the European Parliament)

6 Sept 2023 · STEP

CDP Urges EU to Subsidise Hydrogen Infrastructure and Supply

5 Sept 2023
Topic — Strategic roadmap to double Hydrogen Valleys and increase renewable hydrogen production.
Message — The organisation proposes supporting European electrolyser production through tax measures and incentives. They recommend subsidies for capital and operational costs to attract hydrogen investment. Additionally, they advocate for simpler permitting procedures to accelerate project development.123
Why — These measures allow the institution to lead infrastructure projects using mixed public-private funding.4
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CDP Proposes New Blending Facility for EU Innovation Fund

4 Aug 2023
Topic — This initiative implements changes to the Innovation Fund including new competitive bidding rules.
Message — The organization requests an ad hoc blending facility to combine grants with repayable financing. They urge the Commission to evaluate this facility in the 2025 fund review.12
Why — CDP would gain a formal role managing project pipelines and overseeing investment implementation.3
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

7 Jun 2023 · Digital investments

Meeting with Paolo Gentiloni (Commissioner)

6 Jun 2023 · Discussion on InvestEU and RRF

Meeting with Fabrizio Balassone (Cabinet of Commissioner Paolo Gentiloni)

6 Jun 2023 · Discussion on InvestEU

Italian lender CDP urges faster permits and financing for heat pumps

22 May 2023
Topic — EU plan to accelerate the heat pump market and building renovation.
Message — The organization proposes using blended finance to bridge investment gaps where private markets fail. They also offer to help public authorities simplify and accelerate administrative permit processes.12
Why — The proposal strengthens the institution's role in financing Italy's long-term energy infrastructure.3
Impact — Traditional heating providers lose market share as buildings shift toward electric heat pumps.4
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Response to Interim Evaluation of the InvestEU Programme

10 May 2023

This submission is made on behalf of the Implementing Partners (IPs) Cassa Depositi e Prestiti S.p.A. (CDP SpA) and CDP Equity, which remain fully available to further contribute to the evaluation of the InvestEU Programme by participating in targeted interviews and consultations in the coming months. ************ With the InvestEU Programme, the European Commission (EC) established a strategic partnership with National Promotional Institutions (NPBIs), by allowing for direct access to the EU guarantee. This long-term collaboration enables NPBIs financial capabilities, and knowledge of local markets and investment environment to complement the specific strengths of the EIB Group and International Financial Institutions (IFIs) and generate a positive impact on the EU internal market. CDP Spa and CDP Equity are eager to contribute to the implementation of the InvestEU Programme and are well-prepared to do so. However, notwithstanding the support offered by the EC in the negotiation and early implementation phase of the Programme, adjustments, and further fine-tuning of the rules may be necessary to ensure that the Programme achieves its maximum impact on the EU's economy and reach its policy objectives. More precisely: - Financial aspects: the InvestEU Programme offers various risk-sharing mechanisms to IPs and different levels of guarantee coverage. However, the current provisioning rate set in the InvestEU Regulation may limit financial resources from being used to support more innovative sectors and riskier projects. Moreover, the current design of the InvestEU guarantee seems to favour debt-type over equity-type products, making investments in early-stage companies more complex. To finance high-additionality projects, the EC may consider increasing the provisioning rate in order to offer IPs a higher guarantee coverage (e.g. 80%) and explore a wider range of risk-sharing mechanisms (e.g. FLP). - State aid requirements: current State aid rules are challenging, particularly for IPs who are not public sector entities and typically operate in line with Market Economy Operator Principle (MEOP). While State aid rules are necessary for public subsidy programmes, they are not always suitable for complex financial instruments, as they constrain the action of IPs in areas with a high degree of additionality or where market-based solutions are preferable. The application of State aid rules to IPs requires, therefore, ad hoc compromise solutions, which should be discussed with relevant DG(s). In this respect, only a very low level of support was provided so far to IPs, leaving them in a state of regulatory and operational uncertainty. In addition, not all IPs are required to comply with State aid rules in the same way. National IPs must be State aid compliant, while IFIs and the EIB Group follow the principle of State aid consistency. The different treatment risks compromise the level-playing field between national and international IPs. To address these issues, all IPs should be required to be State aid consistent and allowed to negotiate product-specific clauses to include in each Guarantee Agreement. This would ensure consistency with State aid rules/market-conformity of underlying operations for IPs that already deploy market-conform financial instruments. - Reporting requirements: the InvestEU Regulation requires reporting along three main dimensions (Operational, Financial, and Risk), with additional Complementary reporting requirements. Overall, IPs must report bi-monthly, quarterly, semi-annually, and annually. These reporting requirements are costly for IPs and discourage smaller beneficiaries and may lead to a situation where only large corporates find the InvestEU Programme advantageous. To make InvestEU more accessible to smaller companies, the EC may consider simplifying and further standardising reporting requirements for SMEs/start-ups/small mid-caps, or for all financial products under the SME Window.
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Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

16 Nov 2022 · Meeting on Financial Issues

Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

1 Nov 2022

CDP is the Italian National Promotional Institution and one of the largest Italian financial institutions, with total assets above 410bn. CDP combines financial and industrial capabilities to foster sustainable development in Italy, support growth and boost employment, also spurring innovation, business competitiveness as well as infrastructural and local development. Promoting the circular economy is one of the key target areas of the CDP Strategic Plan for 2022-24, which aims to generate >120bn investment in Italy. CDP intends, inter alia, to support recycling value chains for strategic waste streams, including the development of technologies for the recovery of critical raw materials contained in waste from electrical and electronic equipment (WEEE), which are essential for many technologies contributing to the green transition. In this context, it is worth emphasising that any plan to revise the WEEE Directive should favour investment in the collection, treatment, and recycling of WEEE in order to both prevent adverse impact on human health and environment and contribute to the EU open strategic autonomy.
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Response to Communication on revamping the SET Plan

27 Oct 2022

CDP is the Italian National Promotional Institution and one of the largest Italian financial institutions, with total assets above 410bn. CDP combines financial and industrial capabilities to foster sustainable development in Italy, support growth, boost employment, and spur innovation, business competitiveness, and infrastructural and local development. Through CDP Venture Capital, CDP is contributing to the sustainable growth of the Italian venture capital ecosystem. With >1.8bn AuM, CDP VC is the largest VC asset manager in Italy. By relying on resources made available by the Italian Recovery and Resilience Plan, CDP VC will invest about 250mln in start-ups and innovative SMEs in the green sector, activating at least 250mln of private investments in the same market. CDP welcomes the update of the SET Plan, as research and innovation play a major role in accelerating the green transition, increasing energy security, meeting the EUs energy and climate targets, and achieving carbon neutrality by 2050. In fact, energy transition and technology innovation are 2 key focus areas of the CDP Strategic Plan for 2022-24, which aims to generate >120bn investment in Italy. When it comes to the energy transition, 5 priorities should be reflected in the revised SET Plan: 1.Increasing the weight of renewable energy sources in the energy mix. It is necessary to both increase RES generation capacity and favour the integration of RES in energy systems (by investing in smart grids and develop energy storage systems). 2. Electrifying energy consumption. Priority should be given to the transport and the heating and cooling sectors, with the additional objective of creating strong EU value chains. 3.Fostering energy efficiency. Major opportunities can be created through regeneration projects of existing buildings, the deployment of energy-efficient building technologies (e.g., heat pumps and district heating) and the development of smart building solutions. In addition, energy-efficiency should also be promoted in hard-to-abate sectors. 4. Investing in new technologies and new energy carriers (e.g., hydrogen and biofuels). Innovation requires investing in both infrastructures to produce and transport new energy carriers as well as in hard-to-abate sectors to ensure they rely on these energy carriers for decarbonisation. 5. Promoting energy security. In the current geopolitical context, it essential to diversify energy supply sources and invest in new interconnections with third countries. With regard to innovation, 3 priorities should be reflected in the revised SET Plan: 1. Financing technological innovation. In addition to providing continued financial support to innovation activities performed intra-muros by industrial players, it is essential to nurture the start-up ecosystem, bridge the scale-up gap and support breakthrough innovation. This requires boosting the EU venture capital market, bridge the financing gap experienced by EU start-ups and create more favourable conditions for them to scale up, including through the provision of business acceleration services. 2. Strengthening the innovation ecosystem. Besides investing in research infrastructure, which are essential to push the technology frontier, it is key to create the conditions for technology transfer to happen (especially in deep tech sectors) and transform research results into innovative products and services, which can be adopted at industrial level. 3. Fostering innovation adoption. New technologies need to be quickly adopted. In this context, the diffusion of innovation can be fostered by providing financial support to early adopters, especially SMEs. Furthermore, it is crucial to invest in skills to make sure that business and public administrations understand innovation and make the most of it. CDP stands ready to contribute to the revision of the SET Plan and join the SET Plan community to foster innovation in the green sector and accelerate the energy transition.
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Meeting with Mairead McGuinness (Commissioner) and

31 Mar 2022 · Sustainable finance, digital payments, economic impact of sanctions

Response to Revision of Non-Financial Reporting Directive

12 Jul 2021

Shifting capitals towards more sustainable activities needs to be underpinned by a shared understanding of sustainability, based on accountable and transparent criteria to be measured and monitored through traceable metrics. To this extent, CDP welcomes the European Commission proposal for a better standardization and harmonization of sustainability reporting. This will allow to bridge the gap between the companies’ sustainability disclosure and the needs of the intended users of that information (inter alia large companies, investor, rating agencies, financial companies). The innovative elements introduced by the Proposal are necessary to extend the reporting to a more significant number of companies, ensure an adequate understanding, accessibility and comparability of documents disclosed, and create a consistent and coherent flow of sustainability information throughout the financial value chain. To this extent, we would like to draw attention to some points of the proposal: 1) Standard reporting approach for SMEs. The provision of separate and proportionate reporting standards for SMEs – to reduce the reporting complexity - shall ensure adequate disclosure of the company’s structure and performance in line with users’ needs. For this reason, a potential simplified reporting approach should consider progressivity of requirements (differentiated for micro, small and medium enterprises, considering differences in size/internal structure). Moreover, its introduction should be accompanied by dedicated supporting programs (e.g., reporting templates, contact points, induction sessions to increase SME's non-financial literacy etc.), digital reporting platforms and supporting tools. The second aspect relating to the standard envisaged for SMEs concerns its applicability to unlisted SMEs. The drafting of these standards considers the characteristics of listed SMEs (within the scope of the directive) which do not represent all small companies. Consequently, unlisted SMEs, for which the standard adoption is voluntary, might encounter challenges in complying with these standards, ultimately resulting in a low uptake of voluntary reporting. Hence, the standard designed for listed SMEs should consider the characteristics of unlisted SMEs as well. 2) Standards’ timeline. The proposal calls for a first set of standards, covering the main reporting areas of the CSRD proposal, to be adopted by 31 October 2022. Nonetheless, a second set of standards, covering additional information, including sector-specific information, is expected to be adopted by 31 October 2023. Regarding this timeline, the Commission should consider that it is quite likely that companies will not be ready to report the sector-specific information by 2024. 3) Inclusion of the sustainability information within the management report. The elimination of the possibility for Member States to allow reporting subjects to publish the required information in a separate report is a crucial element to ensure the proper integration and accessibility of information. In addition, there are other key factors to be underlined: 3a) Firstly, it is important to provide guidelines for a proper integration of the relevant documents, to allow for readability and comparability, while avoiding any repetitions and misaligned information. 3b) Secondly, if a company considers different perimeters for financial and non-financial information, it is necessary to know the principles that guided the consolidation of such information within a single document. 3c) Lastly, in relation to digital tagging of sustainability information, according to a digital taxonomy, more details will have to be provided to financial players on how to operationalize this tagging activity in relation to non-financial information.
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

29 Mar 2021 · Green deal and InvestEU

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Since the beginning, Cassa Depositi e Prestiti SpA (hereafter “CDP”) has supported the idea of developing a standardized mechanism to classify sustainable development activities at European Level. CDP therefore welcomes the opportunity to comment on this Delegated Act and deems it as a very important step in the implementation of an effective strategy towards a more sustainable growth model in the EU. However, the original Taxonomy framework – and its implementing process - has been devised before the Covid-19 pandemic crisis that is severely hitting most European countries. In the current scenario, the entire economic system needs a boost to recover, involving also sectors that are either not covered by the Taxonomy or not Taxonomy-aligned yet. Although a swift market adoption of the EU Taxonomy remains a priority, CDP thinks it is important to balance this objective with a need to ensure proportionality in the application - especially in a transitional phase. In particular, with regard to technical aspects of the Taxonomy, it is worth highlighting that data usability might be particularly low in the first year, due to the scarcity of specific information and the lack of implemented processes, both at corporate and Financial Institutions level. To this extent, the terms of adjusting disclosure over time should be decided, in order to allow including some investments that are potentially taxonomy compliant but that, in previous years, had not been included in the Taxonomy-aligned portfolio, due to lack of data or screening capabilities. More in general, companies under NFD obligations will be deeply affected by data collection and analysis challenges, risking not to get the right data from companies that are not in scope of Non-Financial Disclosure. This issue could be particularly relevant in the case of SMEs, for which a specific and proportionate approach should be considered. Lastly on the transition phase, we believe that the fact that certain NACE codes are not yet covered by the Taxonomy could pose a limit to signalling activities significantly contributing to the Taxonomy’s objectives. Therefore, where it is possible to demonstrate the alignment of an activity falling under a NACE not yet included in the Taxonomy - in respect to technical screening criteria devised for a similar activity already included (relevant especially for the manufacturing sector) - such activity could be considered aligned to the Taxonomy, even if not legally compliant with it. In general, the description of the activity included in the technical screening criteria should be the main reference point to assess further activities and their alignment with the Taxonomy (independently from NACE codes). We strongly believe that striking a balance between the Taxonomy’s objectives, the capabilities currently available within the market as well as the role of financial institutions in the recovery, will be crucial to ensure the Taxonomy becomes a key driver of a long-lasting and sustainable growth.
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Meeting with Estelle Goeger (Cabinet of Commissioner Paolo Gentiloni)

3 Dec 2020 · InvestEU

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

4 Sept 2020

Shifting capitals towards more sustainable activities needs to be underpinned by a shared understanding of sustainability, based on clear impact criteria and traceable metrics. To this extent, CDP welcomes the effort by the European Commission to devise a list of assessed and classified economic activities, based on their contribution to sustainability objectives. Disclosure will be a cornerstone of the upcoming EU taxonomy and should represent an opportunity for companies to provide appropriate information for all stakeholders and to structure a sustainable path for the achievement of the SDGs and of the European Climate Plan. To this extent, we would like to draw the attention to some points which will affect clarity, effectiveness and consistency of taxonomy-related disclosure, ultimately impacting on the smooth implementation of the future EU taxonomy as a whole: 1) Consistency of disclosure across non-financial disclosure legislations. Large companies and financial market participants are already subject to several non-financial disclosure regimes - such as NFRD, “Disclosure Regulation”, not least, for some of them, the upcoming InvestEU Sustainability Proofing regime . It is also not clear whether such reporting obligations are different / additional to the taxonomy. To avoid unnecessary administrative burdens and make sure market players are provided with all the relevant non-financial information, consistency should be ensured across the several EU non-financial disclosure legislations, while avoiding additional or conflicting requirements. Otherwise, the risk is to create an informational overload undermining the proper collection and comprehension of relevant non-financial information/phenomena. 2) Simplified reporting approach for SMEs. Although SMEs are not legally subject to the NFRD (hence also to taxonomy-related disclosure), the use of the taxonomy by smaller undertakings represents a key factor for the success of the taxonomy and for a swift transition of the entire EU economy. Indeed, a low uptake of the taxonomy among SMEs (e.g. due to excessive compliance costs) might induce certain financial market participants - willing to offer sustainable financial products - not to consider SMEs, thereby excluding de-facto a large share of companies from sustainable finance. To avert such a scenario, a simplified and voluntary reporting approach for SMEs would be key to keep these subjects within the range, ultimately allowing SMEs to benefit from new sustainable investments opportunities while increasing the information available to financial intermediaries. Such potential simplified reporting approach should be characterized by progressivity of requirements (differentiated for micro, small and medium enterprises, considering differences in size/internal structure) and its introduction should be accompanied by dedicated supporting programs (e.g. reporting templates, contact points/help-desks, induction sessions to increase SME's non-financial literacy etc.). On their side, financial companies should be allowed to rely, for their own disclosure obligations, on such simplified information provided by SMEs. 3) Access to information by financial companies. It is important to highlight that access to relevant information will also be a significant challenge for investors. In this respect, it is worth signaling that, although the Taxonomy Regulation does not require non-financial companies to disclose the proportion of Taxonomy activities that are categorized as “transition” or “enabling”, investors are actually expected to disclose such breakdown. 4) General purpose financing. Finally, it is not clear how to apply Taxonomy to investments, not strictly related to a specific project or activity but devoted to support the BAU of enterprises. An option could be considering general financing as taxonomy-aligned if companies are compliant with predefined minimum transparency, environmental and social issue standards.
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Response to Climate change mitigation and adaptation taxonomy

24 Apr 2020

Shifting capitals towards more sustainable economic activities needs to be underpinned by a shared understanding of sustainability, based on clear impact criteria and traceable metrics. To this extent, CDP welcomes the effort by the European Commission to devise a list of assessed and classified economic activities, based on their contribution to EU sustainability objectives. At the same time, we would like to draw the attention to the following challenges, which will largely affect the practical implementation of the EU technical screening criteria as well as the impact of the future EU taxonomy: 1) Ensure a realistic level of ambition of technical screening criteria. To ensure effectiveness, the technical screening criteria of the EU taxonomy should continue to include broadly activities for a substantial transition in accordance with a 1.5°C or at maximum 2°C scenario (transition activities); indeed, this would be key to ensure an orderly economic and societal transformation, ultimately minimizing negative impacts due to stranded assets. In such perspective, we welcome the TEG’s recommendation to count, as Taxonomy-aligned, improvement measures directed to activities that do not already meet the technical screening criteria (e.g. improving energy efficiency of buildings), when certain conditions are met (ref. par. 2.1.3 TEG Final Report). In this respect, it will be key that such conditions are clearly set. 2) Ensure the practical viability of technical screening criteria. Taxonomy criteria should be clear enough to enable smooth implementation and handling by enterprises and financial institutions - especially by those with no or limited previous experience of such approaches – also by not creating additional burdens to asses compliance with them. Moreover, it is key to ensure usability of the taxonomy as regards to SMEs. Indeed, an adequate approach and/or a system of incentives to keep SMEs within the range of the taxonomy is necessary (e.g. through simplified criteria). Otherwise, if it is deemed too complicated, burdensome or expensive, those financial market participants willing to offer sustainable financial products might not consider SMEs and thereby de-facto exclude them from the taxonomy. Finally, it is important to highlight that access to relevant information will also be a significant challenge for investors. To this extent, stronger non-financial reporting requirements for large corporates (such as more detailed and certified reports, explicit integration of climate risk, etc.) will be needed. Besides it is worth signaling that, although the Taxonomy Regulation does not require companies to disclose the proportion of Taxonomy activities that are categorized as “transition” or “enabling”, investors are actually expected to disclose such breakdown in their own disclosures. 3) Aim for consistency of reporting obligations across Regulations/Directives. Large companies and financial market participants will face new administrative burdens when collecting and disclosing information required under the Taxonomy Regulation (e.g. IT, Internal processes, advisers or in-house specialists etc.). Moreover, at the moment, it is not clear whether such reporting obligations are different / additional to the reporting obligations under InvestEU. In this respect, consistency should be ensured for criteria and reporting under the two regulations. 4) Ensure that clear processes and defined responsibilities are set. Applicability of the taxonomy will require sound and streamlined verification mechanisms with clear processes and defined responsibilities, while procedural requirements must not only be compatible with larger scale project financing but also with small-scale lending and the related processes.
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Meeting with Paolo Gentiloni (Commissioner)

29 Jan 2020 · The European Green Deal Investment Plan and InvestEU and how CDP can contribute to this strategy

Meeting with Daniela Rondinelli (Member of the European Parliament)

29 Jan 2020 · Various

Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

6 Jun 2019 · Long Term Strategy

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

14 Feb 2019 · Sustainable Finance

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen)

27 Sept 2018 · Investment Plan and InvestEU Programme

Meeting with Stefano Manservisi (Director-General Directorate-General for International Partnerships)

18 Sept 2018 · Courtesy visit of the newly appointment Director for International Development and Cooperation at Cassa Depositi and Prestiti

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

12 Jul 2018 · Sustainable Finance

Meeting with Jyrki Katainen (Vice-President) and KfW Bankengruppe and CAISSE DES DEPOTS

28 Jun 2018 · The role of NPBs in the next MFF

Meeting with Stefano Manservisi (Director-General Directorate-General for International Partnerships)

29 May 2018 · European Investment Plan and Financing for Development

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

22 Mar 2018 · Investments in Social Infrastructure in the future MFF

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

22 Mar 2018 · Pubblic affairs

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen)

16 Mar 2018 · Financial instruments in the next MFF

Meeting with Marco Buti (Director-General Economic and Financial Affairs)

22 Feb 2018 · Italy and the EU

Meeting with Jyrki Katainen (Vice-President)

22 Feb 2018 · Investment Plan and next MFF

Meeting with Stefano Manservisi (Director-General Directorate-General for International Partnerships)

16 Jan 2018 · project PASPED Senegal; • Proposed Investment Programme with AECID and COFIDES regarding a proposed Financial Inclusion Facility under the EFSD MSMEs financing investment window

Meeting with Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

8 Nov 2017 · Finanza per il sociale

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

8 Nov 2017 · European Defence Fund

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

19 Sept 2017 · Introducing the new head of the CDP Brussels office

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

18 May 2017 · Investment plan

Meeting with Günther Oettinger (Commissioner) and KfW Bankengruppe and CAISSE DES DEPOTS

12 Dec 2016 · Broadband Fund Announcement

Meeting with Alicja Magda Herbowska (Cabinet of Commissioner Tibor Navracsics), Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

29 Nov 2016 · EFSI in education

Meeting with Stefano Grassi (Cabinet of President Jean-Claude Juncker)

13 Oct 2016 · Investment Plan; External Investment Plan

Meeting with Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

13 Oct 2016 · exchange of views long-term investments and or Capital Markets Union

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

12 Oct 2016 · Presentation of "Cassa Depositi e Prestiti S.p.A."

Meeting with Neven Mimica (Commissioner) and

25 May 2016 · Exchange of views on new ways to finance development

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

28 Apr 2016 · EFSI