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Climate Strategy

Climate Strategy

Climate Strategy is a consultancy providing expert strategy and policy advice on sustainable finance, energy efficiency investment, financial instrument design and climate innovation to support the transition to net-zero emissions.

Lobbying Activity

Meeting with Yvan Verougstraete (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · European Competitiveness Fund

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur) and Orgalim – Europe's Technology Industries

15 Jan 2026 · European Competitiveness Fund

Meeting with Bruno Tobback (Member of the European Parliament)

10 Dec 2025 · The European Competitiveness Fund

Meeting with Valdis Dombrovskis (Commissioner) and

4 Dec 2025 · Industrial Accelerator Act

Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

12 Nov 2025

The Commissions proposal for the next Multiannual Financial Framework (MFF) offers an opportunity to bridge Europes climate investment gaps and crowd-in private capital to strengthen clean industrial competitiveness and improve Europes energy security. Our briefing and recommendations which we attach use an economic efficiency frame to examine the EU budget proposal to ensure that decarbonisation and competitiveness are delivered fairly to beneficiaries using the appropriate instrument (grant or financial instrument). Grants are clearly the most valuable, and scarce, EU budgetary currency, and they have to be reserved to deliver innovation, research, social, climate and other environmental objectives where financial instruments will not work. The European Competitiveness Fund (ECF) is proposed as the one-stop-shop for EU financial instruments and that can extend InvestEU support to grow strategic technologies from lab to scale. Currently, Member State compartments in InvestEU provide an opportunity to deploy EU Financial Instruments as a Service (EU FIaaS) for national and regional authorities. Under the ECF InvestEU toolbox, the impact of funds available under the National and Regional Partnership (NRP) Plans can use this mechanism to crowd-in private investments into mature clean technologies and solutions. The following four core building blocks can drive a strategic and efficient design of climate and competitive investments in the next MFF: 1. An evidence-based approach to the ECF Work Programmes should build on two pillars: first, an expert-led governance framework with independent input, and second, a science-based assessment of sectoral decarbonisation pathways and associated investment gaps to identify investment priorities. This should reflect that industrial investments only represent 5% of the total investment gap to reach net zero by 2050, while clean industrial leadership will depend on the uptake of these technologies in the real economy via business actors and households to decarbonise sectors with the highest investment gaps (transport, buildings and agriculture). 2. A targeted supply-chain approach in ECF Work Programmes will serve to identify the financial instruments needed by clean technologies and solutions in a specific sector. An improved additionality principle can help identify what are the needs of the end-beneficiaries across the supply chain, and which ones require these instruments most. An effective growth strategy for cleantech will also require that ECF Work Programmes boost the uptake of clean technologies and solutions by end-consumers, including smaller businesses and households. 3. Integrating an efficiency-first approach in Member States NRP Plans can increase the use of financial instruments under funds under shared management, which historically has been low. Offering asset-specific EU FIaaS in the ECF InvestEU can simplify this task for national and regional authorities and tap into higher leverage and lower funding costs. Driving demand for the ECF InvestEU Member State compartment will require: first, clarifying the connectivity between the NRP Plans and the ECF InvestEU and facilitating access to this instrument for both national and regional authorities; and second, establishing mandatory conditions and incentives for the development of granular financial assessments that determine when grants are needed for achieving NRP objectives, and when EU Financial Instruments via ECF InvestEU are the preferred approach. 4. A simplified delivery of EU funding will require different approaches: a) European cleantech can benefit from a proactive outreach led by the EIB as the Climate Bank under the new SME initiatives in the ECF; b) the wider fabric of SMEs, and households, need the lead of national promotional banks and competitive local retail channels to deliver EU FIaaS under ECF InvestEU and in close coordination with NRP Plans.
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Meeting with Alexandr Hobza (Cabinet of Executive Vice-President Stéphane Séjourné)

15 Oct 2025 · Discussion on the next Multiannual Financial Framework (MFF), following a publication by Climate Strategy of a briefing ‘Towards an evidence-based and efficient design of climate and competitive investments in the next MFF’

Meeting with Radan Kanev (Member of the European Parliament)

24 Sept 2025 · Launch of MFF Report

Climate Strategy Urges Reform Before Expanding Industry Energy Subsidies

5 Sept 2025
Topic — This consultation reviews technical updates to state aid guidelines for industrial electricity costs.
Message — The organization opposes expanding compensation to new sectors without fundamental structural reforms to the scheme. They recommend limiting aid to zero-emission electricity and earmarking at least half of the funds for climate action.123
Why — A stronger carbon price signal directly supports the consultancy's mission to accelerate the net-zero transition.45
Impact — Climate initiatives lose essential funding as carbon revenues are diverted to subsidize heavy energy users.67
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Climate Strategy urges CBAM extension to indirect emissions by 2027

26 Aug 2025
Topic — A consultation on extending the Carbon Border Adjustment Mechanism to downstream products and preventing circumvention.
Message — The group requests including indirect emissions in CBAM and reforming electricity cost compensation. They support expanding the mechanism downstream and using country-based default values.12
Why — These measures would protect clean industrial investments by removing competition from carbon-intensive imports.3
Impact — Fossil-reliant industries would lose the financial advantage of current compensation schemes for dirty electricity.4
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Climate Strategy Urges Smarter Grids and Funding Reform

5 Aug 2025
Topic — The European grid package aims to modernize, digitalise, and expand EU energy infrastructure.
Message — They recommend replacing old connection rules with a system that favors projects ready for implementation. They also call for financial incentives and easier access to funding for grid operators.12
Why — Modernizing the grid would resolve infrastructure bottlenecks hindering the organization’s climate transition goals.3
Impact — Unprepared energy projects would lose their priority in the grid connection queue.4
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Meeting with Julia Lemke (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Petra Nemeckova (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

16 Jul 2025 · MFF post 2027 and European Competitiveness Fund

Meeting with Rosalinde Van Der Vlies (Director Energy)

10 Jul 2025 · Energy Efficiency, Building Renovation Financing and related policy measures

Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič) and Institute for Climate Economics

10 Jul 2025 · Climate financing, in the context of MFF and CTIP

Meeting with Elina Laurinen (Cabinet of Executive Vice-President Raffaele Fitto), Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

9 Jul 2025 · Efficiency in the next MFF for climate and competitiveness

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Environmental Coalition on Standards and

7 Jul 2025 · Letter with 16 signatories for European Competitiveness Fund to deliver climate and energy security for EU citizens and SMEs

Meeting with Anne Funch Jensen (Cabinet of Commissioner Piotr Serafin)

10 Jun 2025 · Exchange of views on the future Multiannual Financial Framework

Response to European Affordable Housing Plan

3 Jun 2025

Climate Strategy (CS) welcomes the opportunity to contribute to the European Commissions Affordable Housing Plan, focusing on boosting investments in building renovations to improve housing affordability for low- and middle-income households. CS highlights two key instruments: Mortgage Portfolio Standards (MPS) and the EU Renovation Loan (ERL). The Plan should be integrated within the National Building Renovation Plans (NBRPs) under the revised Energy Performance of Buildings Directive (EPBD), which mandate consideration of energy poverty and affordability, as referenced in Article 24 of the Energy Efficiency Directive (EED). These frameworks offer the ideal policy space to align energy, climate, and social objectives. MPS are a proposed voluntary framework to encourage banks to decarbonise their mortgage portfolios. By tracking the energy performance of buildings tied to loans, banks can identify climate risks, target the worst-performing properties, and unlock private capital for renovations. The upcoming Delegated Act under the EPBD will define the structure of MPS, including safeguards for vulnerable households through blended finance. The ERL addresses affordability and access-to-finance barriers, especially for vulnerable groups like pensioners and low-income families. By leveraging EU guarantees via InvestEU and the Social Climate Fund (SCF), the ERL would enable long-term, low-interest loans for deep renovations, repayable upon sale or transfer. This tool targets households typically excluded from traditional financing, offering a fair and scalable solution to energy poverty. Both MPS and ERL support the implementation of NBRPs and help Member States meet 2030, 2040, and 2050 renovation targets. These instruments respond to the ECs call to integrate energy and social policies, limit regulatory burden, and ensure fair treatment across regions and populations. The SCF, with a budget of 86.7 billion, cannot meet renovation needs through grants alone. Blending it with private finance through instruments like ERL enhances impact and leverage. The CRREM tool supports this approach by helping banks and asset managers assess climate alignment and avoid stranded assets. In conclusion, the combination of MPS and ERL provides a comprehensive approach to affordable, sustainable housing. MPS mobilises market-wide transformation in finance, while ERL ensures equity and access for vulnerable households. Embedding these tools in NBRPs, SCPs, and NECPs will support an ambitious and socially just renovation wave across the EU. The EU now has an opportunity to lead with targeted, effective, and scalable instruments that transform its housing stock into a source of economic stability and climate resilienceensuring that no household is left behind in the transition to a sustainable future.
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Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

13 May 2025 · Clean Industrial Deal to deliver a Joint Decarbonisation and Competitiveness Roadmap

Meeting with Damian Boeselager (Member of the European Parliament)

29 Apr 2025 · Competitiveness

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Cleantech startups and scale-ups in Europe face significant challenges, including limited access to funding, fragmented regulations, weak market demand, and difficulties in attracting talent and accessing infrastructure. Additional hurdles include misalignment between innovation and industrial policy, uneven public financing, slow digital adoption, and ineffective public procurement for emerging technologies. To address these issues, the EU and Member States should increase funding, simplify regulations, enhance market access, support talent mobility, and expand research and innovation infrastructure. See attached more specific input to the designated questions.
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Meeting with Elisa Roller (Director Secretariat-General)

17 Mar 2025 · Discussion on EU Financial Instruments for Cleantech and Climate Investments

Climate Strategy urges mandatory green standards in EU procurement

7 Mar 2025
Topic — The EU is evaluating the effectiveness of its current public procurement directives.
Message — The group argues for replacing the lowest-price focus with mandatory sustainability and resilience standards. They suggest embedding circular economy principles and specific requirements for green steel in public contracts. They also recommend aligning procurement rules with EU energy efficiency targets for building renovations.123
Why — Mandatory green standards would boost demand for the firm’s specialized climate policy consulting services.45
Impact — Low-cost, high-carbon manufacturers lose competitive advantages as price-only bidding becomes restricted.67
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

Climate Strategy welcomes the recognition of sustainability, resilience and innovation criteria as key drivers for Europes industrial competitiveness and economic growth, and for the accelerated deployment of renewable energy to meet our climate and energy targets. You can find attached a set of recommendations aimed at ensuring robust support across Member States to strategic net-zero technologies made in Europe.
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Response to Implementing Act for guidelines on strategic projects

20 Feb 2025

Climate Strategy welcomes the Commissions efforts to strengthen the manufacturing of pre-selected strategic net-zero technologies to drive Europes industrial competitiveness and climate transition. We recognize the importance of these guidelines to support national authorities in this mission and ensure a uniform approach across Member States. Attached you can find Climate Strategy's recommendations which are aimed at ensuring consistency across Member States and reducing barriers for smaller and innovative European cleantech companies.
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Meeting with Caroline Vandierendonck (Head of Unit Budget)

7 Feb 2025 · The STEP task force met with P. Sweatman & Adriana Rodriguez, representing the Climate Strategy and partners. Climate Strategy presented their organisation & their report "Filling the EU Climate Investment Gap more Efficiently"

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas)

3 Feb 2025 · Report by Climate Strategy: "Filling the EU Climate Investment Gap more Efficiently."

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

16 Jan 2025 · Financing of environmental policies

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

16 Jan 2025 · Incentivising investments in the energy sector

Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

16 Jan 2025 · Presentation of the Filling the EU Climate Investment Gap more Efficiently report

Meeting with Marcel Haag (Director Financial Stability, Financial Services and Capital Markets Union)

15 Jan 2025 · Meeting request by Climate Strategy to discuss the main findings of their new report on "Filling the EU Climate Investment Gap more Efficiently"

Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen), Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

15 Jan 2025 · Filling the EU Climate Investment Gap more Efficiently

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

15 Jan 2025 · To discuss the findings of Climate Strategy's report new report "Filling the EU Climate Investment Gap more Efficiently".

Meeting with Sofja Ribkina (Cabinet of Commissioner Valdis Dombrovskis)

15 Jan 2025 · Next MFF and climate investments

Meeting with Claudia Fusco (Director Environment)

15 Jan 2025 · Presentation of their report "Filling the EU Climate Investment Gap more Efficiently".

Meeting with Nicolás González Casares (Member of the European Parliament)

15 Jan 2025 · energy efficiency

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

14 Jan 2025 · Exchange with Climate Strategy on the report "Filling the EU Climate Investment Gap more Efficiently"

Meeting with Kurt Vandenberghe (Director-General Climate Action)

14 Jan 2025 · Discuss the main findings of the "Filling the EU Climate Investment Gap more Efficiently." report; we hope will be able to inform the new Commission's ideas for the next MFF, the Clean Industrial Deal and the European Competitiveness Fund.

Meeting with Rasmus Nordqvist (Member of the European Parliament)

14 Jan 2025 · Filling the EU Climate Investment Gap more Efficiently

Response to Establishment of a portfolio framework to increase lending towards energy performance renovations

24 Oct 2024

Climate Strategy & Partners (CS) welcomes the opportunity to take part in the European Commission (EC) call for evidence for the initiative Energy efficient buildings: portfolio framework to increase lending for energy renovations. This document responds to segments a, b, and c taking as a basis our latest publication Mortgage Portfolio Standards: The EPBD Delegated Act process can synchronise regulatory developments, climate initiatives, and EU technologies to offer a window into the future which responds to the drafting of a Delegated Act for the voluntary uptake of Mortgage Portfolio Standards (MPS) as stated in Article 17 (paragraph 10) of the April 2024 formal adoption of the EPBD: By 29 May 2025, the Commission shall adopt a delegated act in accordance with Article 32 supplementing this Directive by establishing a comprehensive portfolio framework for voluntary use by financial institutions that supports lenders in targeting and increasing lending volumes provided in accordance with the Unions decarbonisation ambition and relevant energy targets, in order to effectively encourage financial institutions to increase lending volumes provided for energy performance renovations. The actions set out in the comprehensive portfolio framework shall cover increasing lending volumes for energy renovations and shall include suggested safeguards to protect vulnerable households through blended funding solutions. The framework shall describe best practices to encourage lenders to identify and act upon the worst-performing buildings within their portfolios. The CS publication mentioned above, identifies key energy efficiency related elements and provides a way to synchronise them under an all-encompassing future-looking MPS for the purpose of speeding up the mass renovation process of EU buildings through the use of the latest EU-funded technologies, and in turn delivering decarbonisation targets while ensuring a just transition for all Europeans. The CS publication analyses the synergies between the EPBD and the Energy Efficiency Directive (EED), particularly Article 17 of the EPBD, article 30 of the EED, and the Commission Recommendation on Article 30 of the EED and its annex. Developed by CS over the last four years, the momentum for MPS continues as there are global decarbonisation initiatives with aligned targets with the recast EPBD to promote the voluntary uptake of Mortgage Portfolio Standards, and these also support banks delivering against EU decarbonisation and sustainable finance standards, and positioning the EU as a global leader. Also, decarbonisation pathways calculated using specialist EU funded technology providers will enable mortgage lenders to have a clearer perspective of the depth of the renovations needed by the properties they lend to, hence preventing future stranded assets in their portfolios. 2024 is a positive year for energy efficiency. The adoption of the recast EPBD and EED provides a new level of objectives, standards, templates, and definitions that brings clarity for governments, financial institutions, and technology providers on the next steps required to decarbonise European buildings. The European Commission has an opportunity to make the delegated act on the voluntary uptake of Mortgage Portfolio Standards (MPS) future-oriented. Yet, 2024 has also seen political turmoil with social discontent directed at high energy prices, energy poverty, and falling standards of living. Mortgage Portfolio Standards can serve as a union-wide mechanism to extend energy efficiency finance at scale and identify disadvantaged Europeans among retail bank networks. Complemented with the promotion of public guarantees to enable EU Renovation Loans (ERLs), MPS can help mitigate and manage the multiple negative social and energy effects of a dated building stock and create long sustainable jobs, and increase the habitability and value of properties, thus improving the lives of their occupants.
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Meeting with Barry Andrews (Member of the European Parliament) and WindEurope

23 Oct 2024 · Wind Energy

Meeting with Benedetta Scuderi (Member of the European Parliament)

23 Oct 2024 · MFF

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

10 Jul 2024 · Financing the transition

Meeting with César Luena (Member of the European Parliament)

2 Jul 2024 · Climate funding

Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

Climate Strategy & Partners (CS) welcomes the opportunity to take part in the European Commission (EC) call for evidence Assessment of the energy efficiency public funding support at Union and national level, and suitability for the establishment of a dedicated mechanism at Union level. Please download our full response (PDF) which takes as a basis our latest publication Engaging Retail Lenders in Home Renovation: Turning Sustainable Finance Commitments into Household Energy Savings and Climate Resilience calling for EU mortgage lenders to play a more proactive role in unlocking the trillions of home equity stored in the buildings owned by their clients through the voluntary uptake of Mortgage Portfolio Standards (MPS). As reference, on January 15th of this year MPS, was included in the recast of the Energy Performance Building Directive (EPBD), whose final version was adopted in the EU Parliament Industry Committee (ITRE). Introduced as a voluntary measure in the final EPBD, 'mortgage portfolio standards were defined as: Mechanisms incentivising mortgage lenders to establish a path to increase the median energy performance of the portfolio of buildings covered by their mortgages towards 2030 and 2050, and to encourage potential clients to make their property more energy-performant along the Unions decarbonisation ambition and relevant energy targets in the area of energy consumption in buildings, relying on the definition of sustainable economic activities in the EU Taxonomy. We believe there is momentum for MPS as the recast EPBD tasks the EU Commission with the adoption of a Delegated Act (DA) over the course of 12 months to establish voluntary Mortgage Portfolio Standards via: a comprehensive framework portfolio, of voluntary use by financial institutions, to encourage them to increase volumes provided for energy performance renovations. Furthermore, our research finds that at present, over a third of the top-30 banks in Europe already have a form of voluntary Mortgage Portfolio Standard, or equivalent, in place. The September 2023 Energy Efficiency Directive (EED) recast establishes a legally-binding target to reduce the EUs final energy consumption by 11.7% by 2030. MPS can serve as the union-wide mechanism to deploy investments for energy efficiency at scale, as it would assist lenders identify the low-hanging fruit and the climate risks in their property backed loans, more efficiently deliver their own sustainable finance and net-zero commitments, and in turn unlock the potential for sustainable energy efficiency investments needed in Europe. In addition, as referenced in Article 30, the EED recast expects specific focus to be dedicated to increasing the deployment of financial instruments, including debt financing and public guarantees. Therefore, our response also details the concept of an EU Renovation Loan (ERL) (also found in the CS report) meant to provide options to financially underserved communities, especially older homeowners and working-poor families, and how it can complement MPS in meeting the target above. Meeting the ambition of the EED will require a sound framework reflecting the progression of the EPBD, its DA on MPS, coupled with the promotion of ERLs. This exercise can deploy the necessary investments for energy efficiency in buildings at scale and contribute towards 2030 and 2050 climate targets.
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

23 Feb 2024

Climate Strategy & Partners (CS) welcomes the opportunity to take part in the European Commission (EC) call for evidence for the initiative Unlocking private investment in energy efficiency guidance to Member States and market actors. Please download our full response (PDF) which takes as a basis our latest publication Engaging Retail Lenders in Home Renovation: Turning Sustainable Finance Commitments into Household Energy Savings and Climate Resilience calling for EU mortgage lenders to play a more proactive role in unlocking the trillions of home equity stored in the buildings owned by their clients through the voluntary uptake of Mortgage Portfolio Standards (MPS). As reference, on January 15th of this year MPS, was included in the recast of the Energy Performance Building Directive (EPBD), whose final version was adopted in the EU Parliament Industry Committee (ITRE). Introduced as a voluntary measure in the final EPBD, 'mortgage portfolio standards were defined as: Mechanisms incentivising mortgage lenders to establish a path to increase the median energy performance of the portfolio of buildings covered by their mortgages towards 2030 and 2050, and to encourage potential clients to make their property more energy-performant along the Unions decarbonisation ambition and relevant energy targets in the area of energy consumption in buildings, relying on the definition of sustainable economic activities in the EU Taxonomy. We believe there is momentum for MPS as the recast EPBD tasks the EU Commission with the adoption of a Delegated Act (DA) over the course of 12 months to establish voluntary Mortgage Portfolio Standards via: a comprehensive framework portfolio, of voluntary use by financial institutions, to encourage them to increase volumes provided for energy performance renovations. Furthermore, our research finds that at present, over a third of the top-30 banks in Europe already have a form of voluntary Mortgage Portfolio Standard, or equivalent, in place. The September 2023 Energy Efficiency Directive (EED) recast establishes a legally-binding target to reduce the EUs final energy consumption by 11.7% by 2030. As part of an enabling framework to scale-up the market for energy efficiency investments, MPS would assist lenders identify the low-hanging fruit and the climate risks in their property backed loans, more efficiently deliver their own sustainable finance and net-zero commitments, and in turn unlock the potential for sustainable energy efficiency investments needed in Europe. In addition, as referenced in Article 30, the EED recast expects specific focus to be dedicated to increasing the deployment of financial instruments, including debt financing and public guarantees. Therefore, our response also details the concept of an EU Renovation Loan (ERL) (also found in the CS report) meant to provide options to financially underserved communities, especially older homeowners and working-poor families, and how it can complement MPS in meeting the target above. Meeting the ambition of the EED will require a sound framework reflecting the progression of the EPBD, its DA on MPS, coupled with the promotion of ERLs.
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Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

21 Feb 2024 · Investment for building renovations

Meeting with Clara Aguilera (Member of the European Parliament)

14 Feb 2024 · sustainable transition and technology in agriculture

Meeting with Jordi Solé (Member of the European Parliament)

13 Feb 2024 · To present their work and to better understand our vision of key European energy and climate policies

Meeting with Alicia Homs Ginel (Member of the European Parliament)

13 Feb 2024 · Just transition, SMEs, and employment

Climate Strategy urges wider bidding for strategic net-zero sectors

7 Aug 2023
Topic — Consultation on implementing changes to the Innovation Fund, specifically competitive bidding procedures.
Message — The organization recommends expanding competitive bidding beyond hydrogen to include strategic net-zero sectors and adding energy security criteria. They also advocate for an always open application process to better support smaller innovators.123
Why — Expanding the fund and improving its coordination increases the demand for their strategic advisory services.45
Impact — Large established firms would lose the relative advantage they currently hold over smaller, more agile competitors.6
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Response to Review report on the Governance Regulation of the Energy Union and Climate Action

3 Aug 2023

The current geopolitical context shows the urgency of accelerating decarbonisation efforts not just for the sake of our planet, but also to support the EUs energy security and global competitiveness. The Ukraine invasion, the energy crisis and the consequent spiralling inflation highlight the unsustainable dependence of our economies on fossil fuels. At the same time, the US and China are taking unprecedented steps in the support and investment of clean technologies, kickstarting a global race in a market likely to reach $650 billion by 2030, to which a strategic, targeted and impactful response from the EU is required. The EU climate and energy regulatory framework has also undergone significant transformations - the establishment of the European Climate Law, a long-term climate neutrality goal within the EU, and the introduction of the Fit for 55 and REPowerEU packages. The Governance Regulation adopted ahead of these new circumstances in 2018 is therefore unfit for purpose, in terms of effectiveness, efficiency, relevance, coherence and EU added value. To address this, the revision of the Governance Regulation should incorporate economy-wide national climate neutrality deadlines for each Member State. Moreover, it should include national climate neutrality objectives, national binding energy objectives, and national binding sectoral objectives for both ESR and non-ESR sectors. More specifically, the Governance Regulation revision should guarantee that energy savings are put first by Member States as the most cost-effective measure to decarbonise and provide security to industry and households. Energy efficiency gains have slowed significantly since 2015, and the rate at which the building stock improves its energy performance remains at just 1%, even as EU policy goals require this figure to triple between now and 2030. Currently, the Governance Regulation provides insufficient incentives for Member States to make appropriately ambitious pledges regarding their national contribution to the overall energy efficiency target and does not set a sufficient framework in case national contributions do not add up to the EU target. We recommend a revision of the Governance Regulation that: - Sets a binding linear trajectory for the national energy efficiency contributions to make sure that Europe gets quickly on the right track and achieves its new binding target. Clear and binding national targets and mandates for renewable energy generation have led to a substantial increase in the share of renewable production, yet energy efficiency targets for Member States remain indicative. In practice, this means that energy efficiency is neither put first by Member States, nor then by most building owners and businesses. - Establishes target tracking mechanisms to ensure accountability and execution of energy efficiency and building renovation plans to put pressure on the current backlog and lack of implementation of national plans. - Extends the ambition gap and gap filling mechanisms, as per revised Energy Efficiency Directive to primary energy consumption, and clarifies and better aligns the processes of the ambition gap mechanism for the next NECP cycle (such as new reporting obligations and better tracking mechanisms). - Supports Mortgage Portfolio Standards (MPS), mentioned in the European Parliament vote on the European Performance of Buildings Directive (EPBD) recast, and in the opinion of the European Central Bank (ECB) on the EPBD. MPS is a regulatory mechanism where banks pledge to work with their clients to increase the energy performance of the buildings which back their mortgages along a science based trajectory for their portfolio. MPS can align mortgage lenders with EU decarbonisation objectives, by accelerating financed offers for energy efficient renovations.
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Response to European Sustainability Reporting Standards

7 Jul 2023

Making GHG emissions reporting subject to materiality assessments neglects the market demands for greater transparency and the economic benefits that energy and resource savings could bring to private actors. 1. GHG emissions are universally material. Subjecting them to materiality assessments sends the wrong signals and incentives in a fast-paced geopolitical context where a competitive race is underway to reward and boost those companies that provide the most innovative low carbon solutions. Obliging companies to calculate and report their GHG emissions will enable them to identify carbon-intensive hotspots in their activities and get on board in this race to develop and invest in clean technologies. Otherwise, European companies risk losing their competitive edge in a global market likely to reach $650 billion by 2030. 2. Investors are asking for greater data transparency in order to comply with their own reporting obligations and implement sustainability investment strategies in line with the SFDR expectations and their global decarbonisation commitments. Investors cannot omit GHG emissions for the calculation of their principal adverse impact indicators in the SFDR. However, research shows that GHG emissions disclosure lacks quality and comparability, as frequently companies do not disclose a significant part of their emissions. Making this metric mandatory will avoid the risks of greenwashing and provide complete data for investors to effectively channel money to the most advanced and ambitious actors leading in the innovation of solutions for the global energy transition. See report: https://shorturl.at/aS568 3. Large companies subject to the CSRD are also drivers of change across their supply chain, where most blind spots exist and where the biggest challenge lies to fully decarbonise Europes economy in line with its 2030 and 2050 ambitions. By making the disclosure of emissions mandatory, particularly scope 3 emissions, large companies will have to kickstart a climate engagement process with their suppliers in the search for greater transparency and collaborative, innovative solutions to decarbonise their products and services. Business-to-business climate engagement is especially important for Small and Medium Enterprises (SMEs), which are looking for guidance and support in calculating and reducing their carbon footprint. Research by Climate Strategy in Spain shows that 60% of SMEs perceive the risks of climate change to their activities and of increased energy bills as a result of their dependence on volatile fossil fuels (78% have felt the impacts of the energy crisis). Leading SMEs that appear as case studies in our research are already addressing their decarbonisation challenge as a way to gain competitiveness in national and international markets. They are using free, easy-to-use tools that are becoming widely available for the calculation of GHG emissions in smaller companies. However, most SMEs will only be mobilised to use these tools if their larger clients begin demanding greater transparency and greener, resource-efficient products and services. At the same time, leading SMEs are also looking for certifiable green products and services to decarbonise their scope 3 emissions. Therefore, requiring large companies to disclose their emissions will also support SME decarbonisation efforts in Europe by enabling transparent options for green business procurement. 4. Some Member States are already requiring large and smaller sized companies to disclose their emissions, as is the case of Spain in its 2021 Climate Law (for companies with more than 250 employees) and many of its regional laws that are already requiring companies with more than 50 employees to register their carbon footprint. To avoid fragmentation in the European internal market, the ESRS should set the harmonised standard of mandatory GHG emissions disclosure across European companies.
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Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

7 Jul 2023 · The European Renovation Loan - EU level financial instrument for house renovations

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Institutional Investors Group on Climate Change

6 Jul 2023 · The Energy Performance of Buildings Directive

Meeting with Ciarán Cuffe (Member of the European Parliament)

14 Jun 2023 · Finance for buildings

Climate Strategy proposes ten "golden rules" for EU Taxonomy

28 Apr 2023
Topic — This initiative defines sustainable economic activities contributing to European water, circular economy, and biodiversity goals.
Message — The group proposes ten rules to keep the framework aligned with science. They argue basic legal standards should not count as a significant contribution. This prevents gamers from using technical loopholes to find easy green labels.123
Why — Rigorous standards maintain market demand for their specialized expert strategy services.4
Impact — Taxonomy gamers lose the ability to exploit the easiest green labels.5
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Climate Strategy urges EU to boost green innovation investment

13 Mar 2023
Topic — This consultation examines how the EU can achieve climate sustainability by 2050.
Message — The organization calls for a one-third increase in climate-related research funding to meet net-zero goals. They recommend that nearly half of the Horizon Europe budget be dedicated specifically to climate action. They also suggest using trade mechanisms and climate clubs to prevent industrial leakage.123
Why — Increased public funding and market growth in green sectors would benefit its specialized consultancy services.45
Impact — Fossil fuel companies and high-emission foreign exporters would face lost subsidies and higher trade costs.67
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Meeting with Kathleen Van Brempt (Member of the European Parliament)

2 Feb 2023 · Financing the renovation wave: energy renovation loan (APA)

Response to Review of the Construction Products Regulation

11 Jul 2022

CPR must address and create a level playing field for embodied carbon in products in the construction sector as a matter of urgency, starting with cement, steel and metals due to their outsized materiality. For this, CPR must: 1. provide effective solutions to the shortcomings of the CPR standardisation system, notably by establishing criteria for Commission’s intervention, as to facilitate the development of technical specifications even in case of failures of the standardisation system. 2. restrict the scope of the CPR to construction products, shifting cement under the scope of the ESPR, together with all other intermediate products such as steel and chemicals. 3. ensure environmental provisions fully reflect the ambition of the ESPR: - by establishing a structured approach to the development of product and information requirements mirroring the Eco-design process, which will allow to timely tackle products’ environmental hotspots. - by securing a methodology that properly assesses construction products’ environmental impacts, ensuring that reliable and comprehensive information is available to building level WLC calculation. 4. secure the appropriate tools in support of the deployment of sustainable products, including a more integrated approach to end of life. Regarding embodied carbon and alignment with ESPR: Annex I part D provides directly applicable product information requirements. Yet, the parameters proposed do not fully align with the inherent requirements on performance, as it is the case under the ESPR. In particular, art. 7 ESPR (b)(i) requires products to be accompanied by information on the performance of products in relation to an extended list of parameters referred to in Annex I (product parameters). Yet these do not align with the relatively short list of requirements set by the new CPR in its Annex I. To ensure full alignment, the CPR must mirror product parameters set in Annex I ESPR. Carbon footprint is missing as an essential product information parameter. This must be resolved by introducing a full list of product information requirements (Annex I part D) in the CPR based on the full list of inherent product requirements listed in Annex I part C. Green Public Procurement is CRITICAL and the Criteria proposed in art.84 new CPR gives the power to the Commission to develop EU-wide GPP criteria for construction products. Yet, the article does not indicate (1) the scope of the criteria and (2) a timeline for development. Policy makers must: • Avoid setting up a centralised database, and introduce a DPP for construction, reconciliating all information required by the CPR, notably under the Declaration of Performance (DoP) and Conformity (DoC). • Introduce reporting requirements and a ban on unsold construction products within the CPR. • Attempt a reconciliation with end-of-life legislation to ensure tackling impacts all along products’ life cycle. To this regard, introducing EPR schemes for construction can effectively incentivise circularity and internalise responsibility for better end of life management. • Establish a clear and quick timeline for the development of GPP criteria directly applicable at national level, and ensure parameters reflect the full set of information and inherent product requirements set in Annex I of the new CPR. We attach a presentation we gave that highlights some thinking about the role of embedded carbon in the buildings chain and our recommendations to the data elements of that through EPDs.
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Response to Sustainable Products Initiative

20 Jun 2022

We believe that these are key considerations for all "intermediate products" (eg. cement & steel): 1) Introduce mandatory Ecodesign Requirements on information and performance for all relevant performance and lifecycle parameters, communicated via a robust, accessible, and harmonised B2B Digital Product Passport (DPP) system; underpinned by a 'nodata, no-market' principle and a clear legal framework for the disclosure of sensitive business information as well as effective market surveillance. 2) As part of Ecodesign Requirements, adopt Paris-aligned minimum environmental performance requirements to exclude the worst-performing intermediate products based on CO2 footprint and core Product Environmental Footprint impacts. 3) To maximise long-term ambitions and accelerate the phase-out of highly pollutant, energy-intensive production routes, establish ‘2050 classes of performance' to easily communicate the environmental performance of intermediate products and its compatibility with EU and global climate targets for 2050. 4) Introduce minimum functional performance requirements concerning inherent intermediate product characteristics that end-products rely on as minimum quality criteria and the resource efficiency of intermediates placed on the market. 5) Set requirements targeting material composition requirements to foster a non-toxic and circular economy through toxic-free by-design principles, restrictions to foster circularity, and ensure traceability via relevant information requirements. 6) Include mandatory requirements for the assessment of Ecodesign Requirements as a basis for ambitious Green Public Criteria (GPP) for all product groups. The attached file also provides further input and responses gleaned in conversations with like minded think tanks.
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Response to A New European Innovation Agenda

6 May 2022

We published a study in 2019 which provides evidence that the amounts of investment in climate R&I remains insufficient to delivery the EU Green Deal nor a net zero emissions economy by 2050. Even with historic allocations to Horizon Europe, and green earmarking in the Recovery and Resilience Facilities, this remains the case. We attach here a summary of the 2019 findings (as a reminder) in four pages for ease of consideration. We note that EU is missing a framework to boost private sector R&I in "Climate relevant sectors" - these (outside the public domain) like agriculture and buildings materials remain critical for innovation to deliver the EU's climate and energy objectives. Given the invasion of the Ukraine and the clear calls to REPowerEU, we must invest more in key innovative climate related R&I to ensure Europe's energy security in the coming years. Clarity around the definitions of green R&I are required and an extra field marking green in the CORDIS database that tracks Horizon Eurpe project would be very helpful and link to the EU Taxonomy and key EU Energy and Climate technologies.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

18 Mar 2022

Climate Strategy & Partners supports the proposed recast of the Energy Performance of Buildings Directive (EPBD) and provides its full position in full the document attached. Here we summarise our main points: From 2020, CS has been developing the Mortgage Portfolio Standard “MPS” regulatory mechanism. Under an MPS mortgage lenders would pledge to work with their clients to increase the energy performance of the buildings which back their mortgages along a science-based trajectory for their portfolio. This mechanism is fully explained in our report “Underwriting the Renovation Wave with Mortgage Portfolio Standards for Energy Efficiency” October 2021 (found on www.climatestrategy.com). In the EPBD’s December 2021 recast MPS was defined and recommended in Definition 36. (p. 41 EPBD recast) and EPBD Article 15.4, which we support and view as an important foundation to deliver the EU Renovation Wave. Portfolio standards have shown their worth in the regulation of vehicle fleet emissions and to promote US renewables. With MPS properly defined and enforced by the EC through the recast of the EPBD, there is momentum to leverage the power of portfolio standards to help deliver the EU Green Deal. We see MPS as a helpful counterpart to facilitate finance to comply with Minimum Energy Performance Standards (also in the recast proposal) and to align with the Paris Agreement we recommend: - MPS would target a 2050 whole portfolio final destination with interim steps - MPS targets would be aligned with a Paris Agreement trajectory - MPS covers all mortgage lenders and mortgage debt holders (not just banks) - MPS can rely on verified real energy or direct emissions data - MPS rules would include non-compliance penalties Lenders looking to “green” their mortgages through MPS have two compliance strategies: 1. “Renovation compliance route”, renovate each building backing a mortgage in alignment with EU Taxonomy. 2. “Trading-based compliance route”, they could sell their mortgages lent against low EPC rated properties and acquire those lent against highly energy efficient buildings. CS is keen that MS design MPS that promote the former Renovation Compliance Route. The “trading” strategy would – we think - deliver increased incentives for working with clients to renovate their homes and create a virtuous cycle as fewer buyers are found and the discount factors for mortgages to low efficiency properties rise. Compliance with MPS relies on technology as banks will need tools to set and track precise portfolio targets aligned with the Paris Agreement. In the case of commercial real estate, and larger buildings, the Carbon Risk Real Estate Monitor (“CRREM”) is an example of a pathway tool for science-aligned decarbonising, and reducing stranding risks. The EPBD recast is an opportunity to capitalise on cost effectively saving energy, improving building energy performance, delivering into RePowerEU and boosting jobs through renovations. Mortgage Portfolio Standards lever tried and tested regulatory tools to deliver the massive scale financial and operational challenges facing the EU Renovation Wave. CS concludes that Mortgage portfolio standards are already driving transparency and rapid change for those green leaders who are already voluntarily using them, these green shoots need to be extended to cover over 50 mm mortgages in the EU. Mortgage portfolio standards can work efficiently as an element of the EPBD’s article on finance, and if furthered developed can bring lenders to engage and to underwrite the delivery of the EU’s Renovation Wave. In sum: - MPS will align mortgage lenders with the EU Green Deal and Renovation Wave strategy - MPS can address 50 million homeowners immediately - MPS will accelerate financed offers to the low hanging fruit for energy efficient renovations - MPS is a structured way for banks to manage climate transition risk in their mortgage portfolio
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Transport and Environment (European Federation for Transport and Environment) and

26 Mar 2021 · Taxonomy

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Third Generation Environmentalism Ltd and

22 Mar 2021 · Industrial strategy; green transition

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

15 Dec 2020 · Sustainable financing

Response to Climate change mitigation and adaptation taxonomy

11 Dec 2020

Please see the attached brief from Climate Strategy which contains our referenced and argumentad submission. In summary the following provides some overview of that more detailed work: The EU Taxonomy should contain technical screening criteria that ensure sustainable investments are aligned with the Paris Agreement, and rule out greenwashing. A credible and robust climate investment taxonomy must rely on science and the technical evidence assembled by experts over the last two years. Meeting the EU’s increased climate goals requires the rapid realignment and mobilisation of finance at a massive scale. The goal of the EU Taxonomy is to identify investments that make a substantial contribution to climate change mitigation, or adaptation, and avoid harming environmental objectives. A robust taxonomy will also protect the savings of Europe’s citizens against future climate risks and help pension funds avoid investments in what will become stranded assets. Climate Strategy’s briefing paper highlights the strengths of the Commission’s draft, and where it can still be improved. The briefing identifies five main themes: 1. Life-cycle emissions of green power generation must be kept below 100g CO2e/kWh and reduce over time in sync with the EU’s increased climate ambitions to deliver net-zero emissions by 2050. 2. Only bioenergy from advanced feedstocks should be considered and thresholds must be aligned with future revisions to the Renewable Energy Directive. 3. Emissions reduction trajectories can be included in Farm Sustainability Plans, and conversion of carbon-rich soil to forest should be excluded. 4. Expert recommendations need to be reinstated for hydrogen, heat-pump and ammonia production; single-use plastics must be capped; and RDF-combustion excluded from cement. 5. Adaptation investments should be ring-fenced in financial reports, and the flexibility required in adaptation practices should not be used as a green loophole for lower mitigation criteria. Finally, in categories where scientific input has been lacking, like shipping and livestock, the precautionary principle is required. The Platform on Sustainable Finance can develop robust technical screening criteria for the EU Taxonomy in areas where progress to date is insufficient. The EU Taxonomy is the basis for transparent reporting and monitoring on climate spending that has been developed by technical experts. This unequivocal tool is urgently required as public and private sector promoters, project-financiers, companies and Government officials work together to identify investment projects to align recovery investments with the objective of achieving climate neutrality by 2050.
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Meeting with Virginijus Sinkevičius (Commissioner) and

26 Nov 2020 · Presentation of a study on high-impact climate technologies for net-zero emission recovery

Response to Communication on the future of research and innovation and the European Research Area

3 Aug 2020

Last year, the European Commission stated that the achievement of an appropriate European Research Area (ERA) was in progress. Nevertheless, the EC noted that further work was needed to ensure the implementation of its priorities . Moving forward, and in light of the European Green Deal and the COVID-19 pandemic, we would like to make the following recommendations on the Future of the ERA. Aligning the ERA with other EU strategies The Green Deal’s strategy to deliver EU climate neutrality by 2050 has R&I as its cornerstone . As the EU relies on the Green Deal for economic recovery, this will in turn fast-track R&I investments in job-creating sectors like buildings, clean transport and renewable energy. Therefore we recommend the full alignment of the ERA with the EU Industrial Strategy and EU Green Deal itself, and the quick implementation of the SME Strategy, starting with SME-friendly procurement practices and Green Public Procurement. Finding synergies with Horizon Europe / further assistance for green SMEs For the 2021-2017 time period, Horizon Europe will seek to reinforce Europe’s scientific base and the ERA . Over the years, ERA’s research infrastructures (RIs) have been highly successful. From 2020 onwards new world-class RIs will be developed. These will be announced in the ESFRI Roadmap (expected launch: October-November 2021), whose ‘Landscape Analysis’ has as its goals: “to identify the strategic role of the RIs in view of policy developments such as Sustainable Development Goals (SDGs) and Horizon Europe missions ”. Our recommendation is for the ERA and Horizon Europe to find synergies and to align objectives, especially in regards to climate related / green energy efforts. As mentioned in the “Draft proposal for European Partnership under Horizon Europe: European Partnership on Innovative SMEs”, the Eurostars-3 programme intends to provide complementary support to those innovative SMEs promoting breakthrough ideas . In addition, it could contribute to achieving the goals of the Green Deal. We welcome that the EC recognizes the key role of SMEs in the innovation space, as Eurostars-3 is a response to Article 179.1 TFEU. We recommend the EC to draw from the lessons and experiences from ERA’s EURAXESS initiative -an all-encompassing tool-set for researchers-, and apply them to the implementation of Eurostars-3. This would include working closely with National Funding Bodies (NFBs) and the National Project Coordinators (NPCs), connecting the array of stakeholders with green projects, technical assistance, and sources of funding. At present, clean economy SMEs and start-ups are struggling. We can help save jobs now by fast-tracking the allocation of funds through simple reliable platforms where applicants can have access to key data and they can provide assurance of the viability of their projects. About 25% of applications of Eurostars-1 and Eurostars-2 were successful in obtaining funding (an application takes on average 7 weeks to be approved ), yet we need this figure to increase as innovative companies are crucial to the EU’s technological sovereignty, and can also help to preserve Europe’s entrepreneurial culture and its future green economy. Lessons learned from the Coronavirus response We welcome the ERA’s corona platform and its very important work in light of the epidemic. We note that the platform is a one-stop shop which provides funding data pertaining to the Coronavirus. Clearly, Europe is taking the proper steps and needs to make sure that the cooperation around R&I in the health space carries over to the work needed on climate. Our recommendation for the EC is for R&I initiatives to mirror the ERA’s corona platform one-stop shop to offer capacity-building and technical assistance for clean energy technologies like energy efficiency and renewable energy. This would enable to lay the foundation for under way, cross-sector collaborations that will ripple through our society for years to come.
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Meeting with Kadri Simson (Commissioner) and

23 Apr 2020 · How building renovation can contribute to post covid-19 recovery, how to get renovation projects off the ground, how to remove regulatory obstacles and improve advice.

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

22 Jun 2017 · Investment in Energy Efficiency