Energy Efficient Mortgages Hub - Netherlands
EEM NL Hub
The Energy Efficient Mortgages NL Hub (EEM NL Hub) is an initiative from a diverse group of stakeholders in the Dutch residential housing and mortgage market such as lenders, investors, service providers and other institutions.
ID: 078205845652-05
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
4 Dec 2025
The EEM NL Hub consists of 22 members and 19 affiliated members, representing over 90% of the mortgage originators in the Netherlands and many more institutions active in the Dutch mortgage market. The Dutch mortgage market is the 3rd largest residential mortgage market in the EU. The below observations all relate to the CDA from the perspective of financing residential real estate - section 7. Further detail and background is provided in the attached annex that sets out the 10 proposed changes and the full market-based proposal for revising the Taxonomy criteria for residential and commercial real estate finance. Key observations: 1. Renovation criteria are too technocratic and designed in a way that makes practical application impossible. A review would require explicit consideration of data availability and data governance considerations. In this context, the use of fractional loan allocation should not be imposed as this cannot realistically be applied in an economically feasible way to residential loans. See the attachments for concrete suggestions. 2. The Commission should refrain from introducing criteria that are stricter than those established under EPBD (IV.) Although scientifically attractive, stricter thresholds create inconsistent policy signals for homeowners and risk undermining clarity, subsidiarity and proportionality. When criteria or thresholds diverge from, or are more ambitious than, nationally recognised measures or EPBD IV requirements, the associated costs for financial institutions and homeowners increase significantly. 3. For as long as DNSH criteria cannot be assessed at building unit level on the basis of EPC data or any other quantifiable and verifiable source, such criteria should be treated as aspirational observational elements rather than mandatory conditions for alignment of residential loans. DNSH for CCA for economic activity 7.7 and 7.1 is the only exception, since it can generally be assessed for residential properties. 4. We propose making it unequivocally clear that Minimum Safeguards do not apply to loans provided to residential homeowners, as they are not undertakings. This ensures proportionality and avoids unnecessary administrative burdens on individual borrowers. If supply chain due diligence is deemed necessary (as implied through the latest Q&A), it should be addressed through the CSDDD. 5. The CDA does not sufficiently recognise residential homeowners as distinct and central stakeholders, even though residential mortgage loans are both the largest asset class on (FIs) balance sheets and the primary driver of the Green Asset Ratio. Given the Unions legal obligation to achieve a zero-emission building stock by 2050, the Taxonomy should more explicitly reflect the specific realities of residential borrowers and the need for accessible renovation finance for households. 6. When recalibrating activity 7.1 and the renovation TSC, the Taxonomy must duly reflect the substantial jurisdictional divergences in ownership structures, since in some Member States homeowners act as the contracting party whereas in others economic ownership or contractual responsibility lies with the construction company, which materially affects responsibility allocation and the operational feasibility of the criteria. 7. We propose that new residential construction loans should qualify as making a Substantial Contribution (SC) where they meet the NZEB requirements as defined and implemented at national level pursuant to the EPBD. Introducing stricter ZEB related thresholds before the timelines mandated by EPBD IV would create regulatory misalignment. A decisive test of the revised framework will be whether ordinary EU citizens, when applying for a renovation or mortgage loan, can meaningfully rely on these criteria in practice and at scale. This would be consistent with the Budapest Declarations call to reduce administrative burdens and simplify regulatory interaction for citizens and institutions. If t
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
24 Mar 2025
The Energy Efficient Mortgages NL Hub (EEM NL Hub) represents 22 members and 19 affiliated members, accounting for approximately 90% of Dutch mortgage originators and a broad range of institutions active in the Dutch mortgage marketthe third largest in the EU. As such, the Netherlands plays a key role in advancing the EU Taxonomys objectives in real estate finance. On behalf of the EEM NL Hub, we welcome the Omnibus package and the proposed amendments in the Draft Delegated Regulation - Ares(2025)1546172 and its annexes. However, we emphasise the need for a comprehensive and timely review of (section 7 of) the Climate Delegated Act (CDA) and the Disclosure Delegated Act (DDA) to ensure their practical implementation. To date, the EU Taxonomy has primarily reflected the perspective of corporates and financial institutions. While SMEs have received increasing attention recently, the role of homeownerswho, via residential (mortgage) loans, are among the most significant indirect stakeholdersremains insufficiently addressed. Failing to integrate the consumer or homeowner perspective more explicitly weakens the EU Taxonomys real-world impact. Homeowners are critical actors in decarbonising the built environment, and their engagement is essential for expanding sustainable finance. An acceleration of the renovation of the EU building stock is critical to achieving the EUs 2050 climate goals. The EU Taxonomy can play an important role in financing (and thus enabling) this renovation. However, as highlighted in the Platform on Sustainable Finance (PSF) report on simplifying the EU Taxonomy , the current Technical Screening Criteria (TSC) require urgent simplification to be usable in practice. Financial institutions have reported minimal Taxonomy-aligned renovations or constructions, highlighting the complexity of applying the criteria. Most institutions limit their EU Taxonomy reporting to Section 7.7, underscoring the need for pragmatic thresholds to meet Green Deal goals and boost renovations. While science-based criteria are crucial, they must be practical. The current framework prioritises theory over implementation, ignoring data constraints and market readiness. A balanced approach is needed to align with climate goals while ensuring broad adoption without requiring new datasets or methodologies beyond financial institutions' current capabilities. The concept of partial Taxonomy-alignment appears promising but lacks a clear legal and operational definition. Although not strictly within the scope of the CDA, we strongly recommend clarifying that Minimum Safeguards (MS) do not apply to loans for individual homeowners, who are not undertakings. This ensures proportionality and avoids unnecessary administrative burdens for homeowners. If supply chain due diligence is required, it should be addressed under the Corporate Sustainability Due Diligence Directive (CSDDD), which provides the appropriate framework. Applying MS requirements to homeowners is disproportionate and complicates green mortgage loan origination, hindering the scale-up of sustainable finance for renovations. We urge the Commission to incorporate the following: 1. The recommendations outlined in the PSF Simplification Report. 2. The proposals from Ten Changes to Make the EU Taxonomy Revision a Success for Residential Mortgage Loans (attached) . Finally, we stress the importance of a timely review of the CDA and DDA to ensure their practical application in the short term. With respect to the built environment, we like to stress that the revised CDA become applicable before the EPBD IV implementation timeline for member states. https://energyefficientmortgages.nl/wp-content/uploads/2025/02/20250220_EEM_NL_Hub_EUT_Revision_10_Changes.pdf
Read full responseResponse to Establishment of a portfolio framework to increase lending towards energy performance renovations
4 Nov 2024
In the Netherlands, various financing options support energy-efficient renovations, especially during property transactions. Key frameworks such as the Energy-Saving Budget (EBB), Energy-Saving Measures (EBV), specialised mortgage products, and government subsidies facilitate access to financing aimed at improving Energy Performance Certificate (EPC) ratings, promoting energy efficiency upgrades. However, significant challenges remain. Homeowners' Associations (HoAs) face hurdles due to high costs, collective decision requirements, and limited financing options, often hampered by diverse owner priorities and financial capacities. Mortgage financing for renovations also incurs substantial fees for required intermediaries, advisors, and notaries, making these financing routes less accessible. Addressing these transaction costs through subsidies or policy reforms could broaden accessibility and affordability. Moreover, financial institutions lack the legal ownership required to enforce renovations, making homeowner incentives essential. Data limitations under GDPR further impede the development of targeted policies by restricting access to property-specific data. Adjusting these data constraints would support informed decision-making and enhance policy effectiveness. EU Taxonomy alignment poses additional obstacles due to stringent requirements, such as the need for a 30% Primary Energy Demand (PED) reduction, absence of a central renovation record, and complex GAR calculationsall of which increase administrative burdens. The Taxonomys preference for near-Class A buildings may overlook opportunities for improvements in less efficient properties. High DNSH compliance costs further add to the challenge, requiring extensive data collection that can be disproportionate to the value of many residential renovations. Similarly, requirements for Minimum Safeguards verification, particularly for solar panels, impose heavy administrative demands that are impractical for small loans. For improved access to energy renovation financing, simplifying EU Taxonomy criteria could make them more accessible to a broader range of properties, better supporting EU Green Deal goals. Guarantee programmes could also reduce interest rates, making renovation loans more financially viable. Easing GDPR data restrictions for energy policies would enable the government and financial institutions to adopt targeted, effective sustainability measures. Property-tied financing offers another potential solution, attaching renovation costs directly to the property and transferring them to future owners, thus spreading financial responsibility across ownership changes. National-level knowledge sharing among stakeholders would further enhance efficiency and collective progress toward sustainability goals. This framework interacts with several EU regulations, including EPBD IV, which supports energy efficiency standards; the EU Taxonomy and Climate Delegated Act, which define sustainable finance criteria; and GDPR, which governs data accessibility. It also aligns with Securitisation and Green Bond Regulations, which structure financing, and the Mortgage Credit and Covered Bond Directives, which oversee mortgage lending and bonds. For a comprehensive analysis, please refer to the attachment.
Read full responseResponse to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)
26 Feb 2024
We have identified 3 major practical concerns that, when properly addressed, can in our view accelerate private investments in energy efficiency. 1) Current set-up / wording of section 7 of the EU Taxonomy The current version of the EU Taxonomy does not actively support the creation of green renovation loans, it mostly allows mortgage lenders to reward consumers that already own an energy efficient property. Examples of obstacles include: a) The complexity of meeting the Technical Screening Criteria (TSC) for Substantial Contribution for renovation (7.2) b) The complexity of meeting the TSC for DNSH for existing buildings (significantly more guidance required on the thresholds to be applied, or alternatively, the requirement to meet the DNSH criteria to be removed for existing buildings improving the energy efficiency should be given preference and the current set up of DNSH excludes many buildings, making it impossible to offer green financing) c) The fact that even if the TSC of 7.2 have been met, only the economic activity renovation is considered sustainable and therefore the loan amount involved is relatively small and therefore the financial benefit to a consumer limited (insufficient to trigger action or make an impact on the renovation budget) d) The fact that in the most recent Commission Notice on the application of section 7 of the EU Taxonomy a new interpretation / application guideline for the minimum safeguards is introduced, that will make it impossible to demonstrate EU Taxonomy alignment for paragraphs 7.3-7.6 and potentially also 7.7 (consumer to provide evidence that the manufacturer of e.g. the solar panels meets the MSS criteria). A review of the EU Taxonomy that addresses these above barriers is critical to unlocking private finance, given that the EU Taxonomy definitions are being used in more and more other EU regulations. 2) Data availability and data governance Financial institutions need vastly more (technical) data on property level than what is currently available. On the one hand to provide customers with appropriate and correct advice, on the other hand to meet the disclosure requirements in respect of sustainability and climate risk exposure. The biggest obstacles in respect of data are: 1) GDPR: in many countries property data has been classified as personal data and therefore GDPR applies and very strict guidelines apply / significant limitations apply on what can/cannot be done with property data. And although many stakeholders are convinced that in EPBD IV some important steps are being taken, the reality is that the datapoints reflected on an EPC are nowhere near enough information for a financial institution to properly advise customers and meet their disclosure / risk management requirements. 2) Non-existence of the data: much of the data will need to be created and collected. This is expensive and will simply take time, also due to resource constraints in the energy labelling sector. 3) The data that does exist is not standardised and thus non-transferable between different stakeholders. 4) New type of data: mortgage lenders need for instance climate related data on property level to proof DNSH adherence. 3) Development of standardised financial products In the current bank- and insurance capital models, second ranking mortgages or personal finance solutions require higher amounts of capital than first ranking mortgage loans. Also, the capital markets where funding for these products needs to be raised are not yet ready for these products as they are perceived to be more risky than traditional mortgage loans. As a result, there is no true competition in the market on renovation loans: consumers can only obtain private financing with their existing mortgage loan provider in the form of an increase of their existing mortgage loan. In most cases solutions/products from other lenders are too expensive or not allowed under the mortgage conditions of the existing mortgage
Read full responseResponse to Initiative on EU taxonomy - environmental objective
2 May 2023
On behalf of the Energy Efficient Mortgage Hub Netherlands, we welcome the set of new EU Taxonomy criteria and proposed targeted amendments to the Climate Delegated Act. The Technical Screening Criteria (TSC) can contribute greatly towards the EU goal to become the worlds first climate neutral continent in 2050, as enshrined in the EU Green Deal. The renovation of buildings is particularly relevant in this context. Renovating both public and private buildings is an essential action and has been singled out in the Green Deal as a key initiative to drive energy efficiency in the sector and deliver on objectives. We have identified several areas where the adaptation and application of the (amended) Climate Delegated Act and TSC of the four new objectives could be significantly improved in practical effectiveness by considering some minor clarifications and suggestions. We have divided our comments below into questions, observations and suggestions: Question on Appendix A (Objective 1,3,4,5,6). The DNSH criterium for appendix A lists that per economic activity a climate risk and vulnerability assessment (CRVA) must be performed and that an assessment of adaptation solutions must be drawn up. In the context of residential housing, a CRVA can be made and adaptation solutions can be analysed. Adaptation solutions can be designed or implemented on different scales: national, provincial and municipal level and in some cases also on building(unit) level. Q1a: Should the adaptation solutions also be implemented for existing residential real estate? Q1b: To what extent is it allowed to consider adaptation solutions of the government? Q1c: Should adaptation solutions for existing residential real estate be adopted at a building (unit) level? How to do this for e.g. flooding risk. Observations: O1: If only the renovation part (in ) of a (mortgage) loan can be designated in line with SCC 7.2 (or 7.3 and 7.6 respectively) there is less incentive to target energy inefficient properties. This is likely to result in sub-optimal allocation of financial flows: mortgage lenders are more likely to lend to customers that undertake renovations that are (relatively) certain to reach EPC of class A (and thus meet the criteria of section 7.7) and not to customers that own energy inefficient building units that after renovation are not or less likely to achieve an EPC of Class A. as only the renovation loan fraction of the total mortgage loan can be considered for EU Taxonomy alignment and inclusion in the GAR. O2: Section 7.2 describes the 30% improvement of Primary Energy Demand (exc. renewable energy sources). Countries that have implemented the most recent version of the EPBD in the energy performance calculation methodology do not distinguish between PED improvements including or excluding renewable energy per se, as the latter is not an NZEB criterium. When homeowners do an energy efficient renovation in nearly all cases multiple measures are carried out simultaneously. It is, in the majority of cases not possible, from an NZEB-based EPC, to attribute (proof) the PED improvement without the effect of renewables. Suggestions: S1: Section 7.2 is difficult to apply in practice as it is difficult / expensive to demonstrate PED improvement of 30% (excluding renewables) for financial institutions and consumers we suggest omitting the footnote stating that the PED-improvement should be without the effect of renewables. S2: Consider incorporating in the EU Taxonomy (or delegated acts) a more explicit a lawful base that addresses certain GDPR concerns w.r.t access, collection and further processing relevant energy performance data of building (units) and the combination thereof with loan / mortgage data to calculate the GAR. S3: Consider defining an energy efficiency improvement substantial contribution criteria, whereby the whole (mortgage) loan can (temporary) be incorporated in the GAR.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
30 Mar 2022
On behalf of Energy Efficient Mortgages Netherlands Hub:
• Alignment with EU Tax. Climate Delegated Act: The EU Taxonomy does not promote renovations of buildings, but incentives the financing fraction that covers the economic activity of renovation (7.2) or individual measures (7.3 – 7.6). Therefore, the Climate Delegate Act will not incentive renovations evenly (across the EPC / PED distribution). Thereby potentially disincentivising populations living in EPC classes (D – G) properties. Setting concrete renovation targets specifically for the lower EPC classes as envisaged in the EPBD will contribute positively to the Green Deal ambitions.
• Article (1): Previously carried out energy efficient improvements should also be noted and tracked on the (proposed) building passport.
• Article 2(36): The EU Taxonomy (tends to) favors the already relatively energy efficient buildings to be renovated further (so that 7.7(1) status EPC class A can be obtained). Inversely, renovations to buildings that cannot (easily or economically) reach EPC class A are not favored as not the full property but only the economic activity of the renovation is considered to be EU Taxonomy aligned. Furthermore, financial institutions are not the actual owner of the properties , therefore setting standards to the lender does not seem logical. The EBA mortgage credit directive is already investigating the need for energy efficient mortgage standards as part of the mortgage credit directive.
• Article 16(1): EPC’s are costly (avg. €300), shortening the validity might have a demotivational effect on obtaining an EPC (which would also give much needed energy efficiency / improvement advice). We argue to remove barriers on price & validity to a) reach the groups most susceptible to energy poverty ensuring a socially just and equally accessible EPC (and advice) system and b) make it easy to obtain a new EPC even after small energy improvements. To demonstrate the improvements in EPC in a jurisdiction or portfolio, it will be paramount that new EPCs are recorded (i.e. EPCs are updated) as often as possible. Any significant barriers (in terms of validity or costs) should be removed to facilitate this.
• Article 17(5) & 17(6): Legally facilitate, promote or alleviate to (EU) 2016/679 (GDPR) concerns for EPC gathering, processing and (public) access. This will be crucial for the creation and success of NECP renovation plans, MPS, use of building passports, public-private schemes for renovation and the digital building logbook. EPBD III currently leaves it to the member states to interpret the open and public gathering & processing of EPC’s due to national applications of GDPR rules. Thereby effectively obstructing access to the needed EPC data. An EU-wide requirement for countries and lending institutions to disclose this information, would enable them under most GDPR regulations to gather, process and distribute sustainability data.
• Article 16(2): if bottom 15% has been identified and labelled ‘G’, would then (the thresholds for) all the other EPC classes move as well? This would result in the re-distribution of the total property stock every time the new bottom 15% would be determined. We do not see that as a positive as it would make it impossible to set long-term objectives or require complex recalculation of all EPCs. This would be confusing for consumers but also make it very difficult to determine if targets have been met (e.g. MEPS).
• Article 9: MEPS would (need to) trigger (massive) renovation incentives. The renovation incentives are not addressed in the MEPS definition. It seems it is disincentivized as 1) the validity (in years) of inefficient EPC’s is reduced and 2) no financial incentives are proposed. 3) the mortgage portfolio standards incentivise lending to more energy efficient dwellings and 4) as the EU taxonomy only incentives the economic activity of renovation and not the complete loan, there is a sub-optimal incentive from that perspectiv
Read full response