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Climate Bonds Initiative Europe

Climate Bonds’ strategy over the next three years is articulated around four strategic objectives.

Lobbying Activity

Response to European climate resilience and risk management law

3 Sept 2025

The Climate Bonds Resilience Taxonomy (CBRT) provides a science-based, market-ready methodology that can directly enable EU investors and issuers to achieve their climate resilience goals. The CBRT is designed to standardise what qualifies as a resilience investment, tackling the definitional gaps that have so far hindered the mobilisation of capital for adaptation and resilience measures. By creating a clear structuredistinguishing between activities and measures, and between adapted and enabling investmentsthe CBRT recognises both direct resilience actions (e.g. reinforcing infrastructure against flooding) and enabling actions that build broader systemic resilience (e.g. expanding access to climate risk insurance or data services). This nuanced classification mirrors the systemic framing of the EUs Climate Risk Assessment and makes it possible to map risks to concrete investment opportunities across vital sectors such as infrastructure, agriculture, health and natural ecosystems. Each investment under the CBRT must meet three screening requirements that align well with EU climate targets. First, it must make a substantial contribution to resilience, defined in terms of reducing exposure and vulnerability to climate hazards with tangible outputs and outcomes. Second, it must avoid maladaptationensuring that an intervention does not inadvertently increase long-term risks by, for example, locking in inflexible infrastructure or shifting vulnerabilities elsewhere. Third, it must Do No Significant Harm to other environmental or social objectives, including mitigation, biodiversity and social justice. These safeguards make the CBRT highly relevant to the EUs ambition of mainstreaming climate-proofing into all sectoral policies and ensuring consistency across its legislative frameworks - particularly as the CBRT reflects key principles from the EU Taxonomy such as substantial contribution and DNSH. Beyond its methodological strength, the CBRT helps address the very barriers that the Commission has identified as blocking progress on resilience. On the financial side, it provides clarity for issuers and investors by reducing the uncertainty around what counts as a credible resilience project. This lowers transaction costs, supports the issuance of bonds with resilience use-of-proceeds, and facilitates the integration of resilience investments into green and sustainable finance markets. On the informational side, the CBRTs hazard-impact mapping provides a structured way to connect risk assessments to investment outputs, strengthening monitoring and reporting under common EU scenarios. The CBRT also supports pipeline development and market creation, which are central to the EUs competitiveness strategy. By clearly categorising eligible measures and activities, it helps municipalities, utilities, SMEs and project developers identify and bring forward bankable projects in areas such as water resilience, regenerative agriculture, resilient construction and climate risk services. These are the types of markets the EU aims to stimulate in order to drive competitiveness, innovation and job creation. Furthermore, its compatibility with global frameworks positions it as a tool to demonstrate international leadership, aligning EU actions with the Global Goal on Adaptation under the Paris Agreement while setting a benchmark for resilience finance globally.
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Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

The Climate Bonds Initiative (Climate Bonds) is an international, investor-focused not-for-profit organisation working to mobilise global capital for climate solutions. Over the past decade, Climate Bonds has developed a globally recognised, science-based, and interoperable Taxonomy for green bonds. Our criteria are trusted by both issuers and investors for their rigour, usability, and alignment with international climate goals. The Climate Bonds Standard and Certification Scheme is underpinned by our Taxonomy and supported by a network of independent verifiers. Climate Bonds has been instrumental in the expansion of the global green bond market, which has grown from USD 500 million to over USD 3 trillion in outstanding volume. Approximately 7% of all bonds issued in the EU are green, with the Euro area leading globally. Our Green Bond Database is used by fund managers and index providers and is underpinned by screening methodologies aligned with our Taxonomy. Notably, Climate Bonds has provided technical assistance to more than 40 countries in developing their own sustainable finance taxonomies, and advises the International Platform on Sustainable Finance (IPSF). As a long-standing member of the European Commissions Platform on Sustainable Finance (PSF), Climate Bonds has consistently advocated for simplification and interoperability of the EU Taxonomy, recognising these features as critical to usability and scalability. Key Recommendations 1. Keep the EU Taxonomy Central to Sustainable Finance While we support the European Commissions approach to amend the Taxonomy Delegated Acts without reopening the Level 1 Regulation, we are concerned by the proposed reduction in CSRD scope. The increased thresholds (from 250 employees and 50 million turnover to more than 1,000 employees and 450 million turnover) could reduce the number of companies required to report Taxonomy data by approximately 80%. This "de-scoping" risks diminishing the availability of free, public Taxonomy-alignment data for the wider market. Such data is essential for investors and financial institutions to efficiently channel capital towards climate-aligned investments. Taxonomy-based transparency is a public good that enables the development of deep, liquid sustainable finance markets. Without wider applicability of the EU Taxonomy, only the largest corporates may be able to use the EU Green Bond Standard (GBS), potentially limiting its uptake and undermining the EUs ambition to build a thriving green capital market. 2. Make the Taxonomy Simple and Interoperable Since 2020, Climate Bonds has consistently called for a simpler and more interoperable EU Taxonomy. Our experience supporting over 40 countries in taxonomy development has demonstrated that clear, science-based, and modular taxonomies are the most effective in market uptake. One area where simplification is urgently needed is the Do No Significant Harm (DNSH) principle. Currently, DNSH is tethered to EU-specific environmental legislation, limiting its extraterritorial usability. Climate Bonds' approachusing universal metrics and adaptable thresholdsoffers a model for a globally usable taxonomy. Embedding such flexibility into EU regulation would significantly enhance the Taxonomys practicality and global relevance. 3. Enable Partial Alignment Disclosures for Mid-to-Large Enterprises and Public Issuers We recommend introducing a partial Substantial Contribution (SC) alignment disclosure in the current consultation on the Taxonomy Disclosures Delegated Regulation (DDR). This would apply to: Mid-to-large corporates (e.g., those with turnover above 450 million but fewer than 1,000 employees), and Public sector issuers, such as national and development finance institutions. This option would allow these entities to disclose alignment with SC criteria for turnover, CAPEX, and OPEX without the need for full DNSH or Minimum Safeguards alignment.
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Meeting with Gilles Boyer (Member of the European Parliament) and Citigroup Inc.

17 Mar 2025 · Simplification Omnibus

Meeting with Caroline Wellemans (Head of Unit Directorate-General for International Partnerships)

11 Mar 2025 · Exchange on Sustainable Finance and Green Bonds development in low- and middle-income countries

Meeting with Billy Kelleher (Member of the European Parliament)

30 Jan 2025 · Sustainable finance

Meeting with Philippe Lamberts (Member of the European Parliament)

13 Feb 2024 · Keynote conference

Response to Roadmap on REPowering the EU with Hydrogen Valleys

4 Sept 2023

Climate Bonds Initiative highly appreciates the opportunity to provide feedback to the European Commission on the EU roadmap consultation for Hydrogen Valleys. Climate Bonds supports the Commissions efforts to develop a clean hydrogen economy to help the EU reach its REPowerEU objectives and decarbonisation goals.
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Meeting with Paul Tang (Member of the European Parliament, Rapporteur)

1 Feb 2023 · Climate Bonds

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

26 Sept 2022 · EPBD, Taxonomy

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

14 Jun 2022 · RED III

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

15 Nov 2021 · Green bonds

Meeting with Mairead McGuinness (Commissioner) and

6 Sept 2021 · Sustainable Finance

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

23 Dec 2020 · Sustainable financing