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Sustainable Energy Finance Association

SEFA

The Sustainable Energy Finance Association (SEFA) is the European trade association for the sustainable energy industry.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

The Sustainable Energy Finance Association (SEFA) welcomes the opportunity to contribute to the review of the EU Taxonomy Climate and Environmental Delegated Acts from the perspective of practitioners originating, structuring and financing renovation and small-scale clean energy projects in Europes buildings. For our members, the Taxonomy is not a box-ticking reporting exercise: Technical Screening Criteria (TSC) and DNSH requirements directly shape how banks and investors assess renovation pipelines, price performance risk, and decide which projects and portfolios can be labelled, securitised or funded as green. IN SEFA, we call for building-related TSC and DNSH to be fully aligned with the recast EPBD, so that banks and developers are not forced to navigate parallel and sometimes inconsistent frameworks. We highlight that, in practice, new construction is currently much easier to classify as Taxonomy-aligned than renovation, and that the framework risks favouring demolition and high-spec new builds over deep renovation and reuse of existing structures, even where the latter offer better whole-life climate performance. We also flag major data and proportionality challenges: many SME, retail and social-scale renovation projects lack pre-works EPCs or detailed audits, making the current 30% PED test hard to operationalise. SEFA recommends explicitly allowing standardised models and default baselines for small-ticket renovations, using EPBD-based methodologies and building archetype databases, while requiring more robust ex-ante/ex-post performance modelling for large renovation programmes to manage performance risk. Finally, we argue for clearer, more proportionate DNSH evidence pathways for small projects, so that the Taxonomy becomes a workable tool for scaling up deep renovation rather than a barrier to it.
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Response to European strategy for housing construction

18 Sept 2025

The EU must act on both the supply and finance sides of housing construction and renovation. On the supply side, this means building capacity for contractors, simplifying permits and streamlining procurement, promoting standard contract templates, and supporting one-stop shops to pool procurement and aggregate portfolios. Predictable, multi year policies and enforcement of the EPBD will further expand the pipeline of viable renovations. On the finance side, the EU should provide guarantees and blended tools to de risk the renovation phase and the development costs and mobilise public backed insurance to cover construction and performance risks.
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Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen), Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

8 Sept 2025 · Affordable Housing Plan

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

Response to European Affordable Housing Plan

4 Jun 2025

European Commission and the EIB to recognise social housing as a strategic delivery channel for both climate and affordability goals. To make this a reality, the EU must take a more integrated approach across regulation, finance, and implementation. First, the EPBD must be rapidly and fully transposed by Member States, including enforceable Minimum Energy Performance Standards (MEPS) and new buildings requirements and renovations trajectories. These requirements are essential to align long-term investment signals for property developers, construction firms, and institutional investors. Second, affordable access to capital must be ensured. This means enabling social housing lenders and mission-driven investors to access public guarantees, subordinated debt, and credit enhancement instruments that reduce risk and unlock private capital. It also includes scaling green mortgages targeted at low- and middle-income households, tied to energy performance standards, and backed by EU-level credit risk mitigation tools. Third, public support schemes must promote financial neutrality across business models, including leasing, as-a-service, and pay-per-use solutions. Eligibility should be determined by outcomes, not asset ownership. Fourth, tax credits for home renovation should be made fungible, allowing households that cannot benefit directly due to low taxable income to transfer those credits to contractors or service providers. Finally, Member States should be encouraged to establish regional one-stop shops to support municipalities in planning, procuring, and financing sustainable buildings development and renovation. These structures should combine technical, legal, and financial expertise to help public bodies navigate procurement, access funding, and aggregate projects.
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Start-ups and scale-ups are key drivers of clean energy innovation, yet many struggle with access to funding, complex regulations, and scaling within the EU. Financing remains concentrated on large projects, while smaller innovators face high capital costs and often lack the contractual, accounting, and regulatory expertise needed to structure investor-ready projects. Regulatory fragmentation further limits cross-border expansion, making it harder for businesses to grow. To overcome these challenges, SEFA advocates for stronger public-private funding mechanisms, simplified regulations, and deeper integration of the single and capital markets. Key recommendations include expanding public guarantees for smaller projects, incentivizing venture capital for specialized clean energy funds, streamlining permitting and financing approvals, supporting project aggregation to attract investment, and reducing regulatory fragmentation to create a more unified EU market. These measures will help European start-ups scale, compete globally, and accelerate the energy transition.
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Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu)

11 Mar 2025 · Advancing sustainable energy in Europe

Response to Evaluation of the Public Procurement Directives

6 Mar 2025

SEFA Policy Recommendations for Enhancing Sustainable Public Procurement 1.Streamline Procurement Processes Simplifying tender documentation and shortening approval procedures can reduce administrative burdens and make it easier for contracting authorities to prioritize sustainability. Excessive documentation requirements create unnecessary costs for applicants, particularly SMEs. Introducing fast-track pathways for projects that meet rigorous environmental criteria would accelerate procurement timelines and foster innovation. Aligning administrative deadlines with project complexity and using standardized templates would help ensure that sustainability features are integrated early without compromising transparency or competition. 2.Introduce Flexible Financing Solutions To overcome capital constraints, municipalities should have access to blended finance solutions, combining public, private, and EU funds. Creating explicit guidelines for small-scale PPPs would enable municipalities to structure agreements that mitigate risks while advancing environmental goals. 3. Accelerate Digital Transformation Adopting e-procurement platforms and AI-driven analytics can increase efficiency, reduce errors, and improve transparency in public tenders. Integrating digital tools with centralized supplier databases would enhance contract monitoring and foster healthy competition. Investing in blockchain and real-time monitoring systems would further improve accountability and cost controls. 4. Standardize Sustainability Benchmarks The uptake of European Green Procurement Criteria remains uneven, leading to missed opportunities for standardization. Revising the Public Procurement Directive to integrate these criteria would enhance transparency and accelerate demand for sustainable solutions across EU Member States. 5. Adopt More Flexible Framework Agreements Extending framework agreements beyond the rigid four-year limit would help align procurement with the lifespan of infrastructure assets. This flexibility would also allow for the phased introduction of new technologies and emerging suppliers, ensuring that contracting authorities are not locked into outdated solutions. Periodic reviews and built-in checkpoints would sustain progress toward sustainability goals. 6. Strengthen Capacity Building and Training Expanding training programs for procurement officers is essential to equip them with expertise in developing and evaluating sustainable tenders. Peer-to-peer mentorship networks, such as SEFA, can facilitate knowledge-sharing and best practice dissemination. Investing in capacity building would enable local authorities to use procurement as a driver of environmental innovation and economic growth. 7. Leverage Regional One-Stop-Shops for Demand Aggregation Establishing regional hubs that aggregate demand from multiple municipalities can streamline procurement, attract competitive bids, and secure better financing terms. These hubs would centralize expertise in project scoping, financing strategies, and supplier engagement, making it easier for local authorities to implement sustainable projects efficiently.
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Response to Establishment of a portfolio framework to increase lending towards energy performance renovations

4 Nov 2024

SEFA is the European trade association for the sustainable energy industry in the built environment. We are accelerating the transition to a net zero carbon economy by advancing the development and financing of sustainable energy across Europes built environment. The revised Energy Performance of Buildings Directive (EPBD) represents a major advancement toward creating a smart and energy-efficient building sector across the European Union. With a transposition deadline set for May 29, 2026, these new regulations offer significant potential to reduce energy consumption, enhance occupant well-being, and promote a green, digitally integrated future. SEFA welcomes the European Commission s consultation on portfolio framework to increase lending for renovations. SEFA stresses the need for greater investment flexibility for energy efficiency projects and for member states whose ratings are below investment grade. We stress the need for a role of credit enhancement and blended financing in mitigating risk and encouraging private sector involvement in deep renovation projects. In addition, we call for the widening of eligibility criteria for loans to include more extensive elements such as future energy savings, to provide greater access to financing for both residential and commercial building owners. Finally, SEFA stresses the importance of implementing mortgage portfolio standards and improving energy performance data sharing frameworks to help prioritize renovations of the worst performing buildings. Our members' experience shows that, in many markets, the uptake of building renovation is often limited by complex administrative processes and insufficient political incentives, which discourage owners and businesses from taking action. This is why demand for renovation should be supported by clear legislative obligations. The real-life impact can only be seen when legislation such as the EPBD is not only transposed into national law, but also enforced and backed up by supporting measures (financial, procedural, administrative...). Member States need to set clear renovation mandates and soften the complex administrative procedures to create real demand for buildings retrofits. In a nutshell, it is essential that Member States introduce measures and mechanisms that encourage buildings renovation so that the financial tools and measures can reach their full potential and ensure long term impact.
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

The Sustainable Energy Finance Association (SEFA) is the European trade association for the finance of the sustainable energy industry in the built environment. SEFA is the product of three Horizon 2020 projects dedicated to supporting the finance of energy efficiency (EE) and small renewables projects. Over the last 6 years, the team has reviewed over 300 million Euros of such projects and looked to support them in accessing finance. We have summarized some of our learnings below. In setting a course to meet the requirements of the EPBD, eventually renovating millions of buildings, Europe can begin by learning from its successes. Clarity and long-term planning work. For example, building code requirements, which must be met by 2050, already impact investment decisions today. These buildings are owned and/or operated by large asset owners/managers who work with 30-year time horizons. Building codes set up to take effect in 2050 impact their risk analysis, valuation and investment decisions today. Another example would be the results from easy to access white certificates and/or grants for upgrades of specific technologies. There is robust interest on the part of financial institutions to finance this change. However, in order for these institutions to provide funding at scale, increased volume, replicability, and standardization of projects are critical. The shift in focus from individual projects to a portfolio approach has been successful in recent years with large renewable energy projects, and now the challenge is to extend this approach to smaller EE projects. Large-scale private finance of small projects is necessary in order to reach Europe 2030 energy efficiency and carbon reduction targets. According to SEFAs experience, over 80% of the necessary renovations and technology upgrades require an investment of less than 500,000, which is far too small to attract either large project developers or investors. Projects therefore must be developed in a manner, which allows them to be aggregated and traded in bundles. Residential buildings: With Europe having suffered 56,000 heat related deaths in the summer of 2022 alone, upgrading inefficient homes has become even more urgent. For the residential sector in particular, fungible and robust tax credits, perhaps combined with grants and specialized loans will help Member States (MS) to comply with the EPBD. They will also enable them to manage the climate driven health risks, create local jobs and help to ensure that fighting climate change creates growth and promotes economic revival. One-stop-shops: Both residents and local governments would benefit from access to knowledge and support centres concerning energy efficiency upgrades and finance. The European Commission (EC) and MS could consider making these available on a stable and long-term basis to both parties. SME project developers and contractors lack access to growth capital. This is a problem across Europe and consistently reduces their ability to increase sales, hire and train new employees and develop their markets. SEFA is helping one of these establish a special purpose vehicle over which they will have control but can place their projects for finance, increase the valuation of their company and help to grow their business. Public Projects: Public entities must be leading the way by example in this critical area. A lack of knowledge on the part of local governments, along with extended procurement processes are strongly hampering this process. Through centralization of decision making and binding national mandates, MS could begin to overcome these hurdles. The fight against climate change is one of local action producing global results. It is the role of MS and the EC to set the conditions and requirements which enable these local actions to take place.
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