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Triodos Bank

As one of the world's leading sustainable banks, our mission is to make money work for positive social, environmental and cultural change.

Lobbying Activity

Response to European Climate Law amendment

8 Sept 2025

Triodos Bank welcomes the proposed 90% net reduction target for 2040, which we see as a bold and necessary intermediary step in the right direction. Ambitious and clear targets are necessary to secure long term investments in sustainable industries. However the ambition in the proposal risks to be undermined by loopholes that allow for compensation through offshore carbon credits and costly and unproven carbon removal technologies. Triodos Bank thinks that capital must be directed to real homegrown climate innovation solutions that reduce emissions at the source, strengthen energy security and create green jobs in Europe. One of the key loopholes that Triodos Bank would like to see fixed in the current proposal is the allowance for permanent carbon removals to offset emissions. We advocate to separate reduction and removal targets. In practice, removal often refers to carbon capture and storage (CCS), a technology with a long track record of failed projects, cost overruns and underperformance. According to Oxford University, CSS is not just ineffective, it can be highly economically damaging. Crucially, allowing companies to compensate emissions with future carbon removals risks locking in fossil fuel dependency at a time when we need to accelerate the transition to clean energy and circular industry. The proposed legislation should not leave room for creative carbon accounting, finance needs to flow where it is needed: real climate innovation in Europe. Another proposed flexibility is the use of international carbon offsets to meet European domestic climate goals. This goes against the advice of the European Scientific Advisory Board on Climate Change that stressed decarbonisation should and could happen within the EU in its own strategic interest. By relying on offsets, Europe risks delaying meaningful decarbonisation and missing a vital opportunity to modernise its economy, lead in clean tech, and reduce its dependence on fossil fuel imports. Not allowing for the use of international carbon offsets in meeting European climate targets would create more clarity, stimulate more domestic investment in climate solutions, and reduce risks. To increase the chances of reaching the target and to enhance the energy transition, we encourage the European Commission to urge European governments to commit to a legally binging international Fossil Fuel Non-Proliferation Treaty. The FFNPT initiative is a global effort to meet the goals of the Paris Agreement by fostering international cooperation to accelerate a transition to clean energy for everyone, end the expansion of coal, oil and gas, and phase out existing production. This needs to be done in a manner that is both fast and fair, so that no person, community or country is left behind and in keeping with what science shows is needed to address the climate crisis.
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Meeting with Rasmus Nordqvist (Member of the European Parliament) and Intesa Sanpaolo and

25 Jun 2025 · Closed roundtable on financing the circular economy

Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

Our key recommendations towards a simple, clear and comparable system for all investors to shift capital to a sustainable economy 1. Enhance Clarity and Comparability Implement a grading system (1-5) applicable to all financial products to allow for easy comparison, eliminating distinctions between sustainable and non-sustainable products. With varying degrees of sustainable investments, exclusions applied and/or Principal Adverse Impacts (PAIs) included in investment decisions. Introduce standardized PAI indicators for all products to ensure transparency regarding negative impacts. 2. Refine Definitions Harmonize the definition of sustainable investments to ensure more consistency within the market. 3. Revise Disclosure Framework: Shift the focus from entity-level disclosures to product-level disclosures to enhance relevance and clarity for retail investors. Streamline pre-contractual information to ensure it is concise, clear, and comparable across products. 4. Periodic Reporting: Mandate all financial products to disclose key PAIs to enable comparability, establishing sector-based benchmarks for performance. 5. Consider Transition Categories with Caution: If introducing a transition category, implement strict safeguards to prevent greenwashing and ensure genuine environmental improvements. As Triodos Bank, we stand firmly behind the original SFDR objectives of steering capital flows towards sustainable investments, mainstreaming sustainability into risk management and fostering transparency and long-termism. Having four years of experience disclosing according to the SFDR regulatory requirements, we see the following negative effects of the regulation that need to be addressed in the upcoming review of the SFDR: The current SFDR disclosures dont provide clarity and comparability for investors, particularly retail investors. We see that the disclosure documents published on the product websites are hardly read and understood by investors. The market seems to rely on the Article 6, 8 or 9 categorisations mostly, which is, however, limited and not comparable. The regulation allows significant flexibility in how these criteria are interpreted and applied. The SFDR currently does not provide insights in the investments in non-sustainable or even harmful activities. The lack of information on the impact of Article 6 products results in insufficient transparency for investors to make informed decisions and steer capital towards sustainable investments. The focus of the SFDR on disclosures for sustainable products results in an increased financial and administrative burden for those products. This results in an uneven playing field between sustainable and non-sustainable products, because it increases the costs and administrative burdensome of sustainable products only. It also leads to market participants purposely not disclosing sustainable characteristics of their products, also known as green hushing. Both stand in the way of steering capital to sustainable investments. The definition of sustainable investments is too broad and inconsistent. The current SFDR allows market participants too much discretion in determining their own framework for assessing whether sustainable investments meet the "Do No Significant Harm" (DNSH) principle. This results in varying degrees and interpretations of what qualifies as a 'sustainable investment', creating confusion and lack of comparability for retail investors. In the attachment we have added reform proposals to ensure effective revision op de SFDR.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

23 Apr 2025 · EU Omnibus

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

Triodos supports simplification efforts of the Taxonomy that could facilitate green investments, but is critical of this proposal for its scope reduction and the introduction of partial alignment. Moreover, the green agenda of the EU is best served by expanding the Taxonomy to cover all relevant sectors, in particular agriculture. Transparency about gas and nuclear activities should be maintained. This way the Taxonomy remains a centre piece of the green deal supporting sustainable finance across Europe. We dont support a reduction of the mandatory scope for the EU Taxonomy. This poses a serious concern to FIs that rely on that data from undertakings for their own reporting under the SFDR and for investment decisions. The proposed opt-in regime is heavily dependent on the (good)will of undertakings to report on Taxo-alignment when asked for by FIs. Most likely, only large FIs will have the power to incentivize undertakings to report. This means that smaller FIs will have more difficulty in accessing and utilizing Taxonomy alignment information. As to the 10% minimum threshold for activities, we understand that this threshold allows undertakings to focus on only material business activities, but it matters how this 10% is defined. Large undertakings and in particular financial undertakings tend to have widely dispersed product portfolios which would make it easy to hide under the 10% threshold and escape the reporting requirement. We are strongly against the introduction of a partial alignment. While reporting on such partial alignment could support a companys transition pathway and thus provide support to scaling up transition finance, we believe that this proposal adds undesirable complexity to the Taxonomy. If not well defined, it will provide ample opportunity for undertakings to inflate their Taxonomy data. Lastly, the scopes of application vary between different pieces of legislations (TR, CSRD, CSDDD). This is confusing. We propose that the same scope, the one of the Accounting Directive, is applied to all three legislations. We agree that the reporting burden must be manageable and that barriers should be removed. Especially the substantial contribution and DNSH principle pose a challenge, particularly for EM countries. The proposed amendments are not sufficient to address this. The current approach is impeding the implementation by financial market participants investing in EM where capital flows to environmentally sustainable activities are mostly needed. We propose that existing processes for instance required for permits and inspections are aligned with taxonomy requirements. We appreciate the proposed reduction in reporting templates. In Annex IV, the classification of cash items lacks clarity in the current template. We recommend explicitly including cash under row 24 "other counterparties and assets" to eliminate any ambiguity in reporting. In Annex VI, Template T0: column K (100% minus column I) can be removed. Instead, we propose enhancing the usefulness of coverage reporting by repositioning the coverage columns to Template 1, rows 1 (assets covered in both numerator and denominator), 19 (assets excluded from numerator but covered in denominator), and 36 (assets not covered for GAR calculation). This would provide a more accurate representation than the current percentage coverage in column I. Template T1: we appreciate the improved alignment with Annex IV, but we question the necessity of separate breakdowns for loans collateralized by commercial immovable property and building renovation loans (rows 23 and 24). We recommend creating a dedicated row for non-central government exposures that are neither specialized lending nor non-EU, as their current inclusion in row 34 creates potential for misinterpretation. Template T2: columns e-j should refer to aligned assets to prevent any potential confusion. Template T3: the addition of column L is valuable for comprehensive reporting.
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Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné) and Regulatory Communication and European Microfinance Platform

18 Feb 2025 · Omnibus sustainability simplification, Savings and Investments Union

Meeting with Auke Zijlstra (Member of the European Parliament)

16 Jul 2024 · Banking

Response to European Sustainability Reporting Standards

6 Jul 2023

Triodos Bank was looking forward to a robust, mandatory and consistent impact-reporting framework, as advised by EFRAG, to help achieve the Green Deal and informed decisions by banks, insurers and investors. But the ECs draft represents a step back. The CSRD intends to address data gaps across the EU sustainable finance rules. The proposed approach, however, would limit investor access to the consistent, comparable and reliable impact-information needed to inform decisions and allocate capital in line with sustainability goals, incl. of the Green Deal, the Biodiversity Strategy for 2030 and the Climate Law, as well as to comply with obligations in SFDR, Benchmark Regulation and CRR. Disclosure remains the foundation of the EUs Sustainable Finance Action Plan. It is essential that the EC lays the groundwork for mandatory corporate sustainability reporting on key elements across the full spectrum of ESG matters. Without a comprehensive regime in place, companies will struggle to attract capital for their financing, and investors and other financial market participants will continue to struggle to obtain meaningful, comparable and reliable information they need to finance the transition to a sustainable economy. The proposal opens a loophole by allowing companies to leave out important details of their greenhouse gas emissions, biodiversity and workforce data. That would contradict anything the European Union has achieved in the past five years with the Sustainable Finance Action Plan. The EC deviates from the phased-in approach already agreed under the CSRD and introduces a delay for companies below 750 employees, incl. all social standards and the biodiversity standard. This implies that large companies and financial institutions will go and collect impact information from smaller suppliers and clients themselves, increasing confusion on language, complicating comparability and increasing costs for smaller companies. Also, the proposal makes the application of several mandatory disclosure requirements subject to materiality assessment, thus allowing companies to omit entire disclosures, incl. on GHG emissions and workforce data. But for the EUs climate objectives, reporting on GHG emissions, transition plans and climate targets should always be considered material and hence mandatory. This would ensure that investors can access information from their holdings to support the alignment of their portfolios with net-zero and the Paris Agreement targets. Moreover, the ECs proposal turns certain disclosures to voluntary, regardless of their materiality. Companies would not have to report on the use of their non-employed (i.e. primarily agency) workers. Triodos Bank is concerned that the EC overlooks the differences in social protection and other worse conditions compared to direct employees. Finally, the EC makes disclosure of biodiversity transition plans voluntary. EFRAG advised requiring companies from high-impact sectors to describe their plan according to the criteria listed in the standards or transparently declare they do not have a plan of such quality. The EC proposes to delete this minimal obligation, which ignores serious concerns about the harmful impact of certain business on biodiversity. So we call on the EC to stick to the EFRAG advice, and at least to: + Stick to the timelines as agreed in the CSRD. + Maintain key climate disclosure indicators as mandatory, including Scope 1, 2, and 3 GHG emissions and disclosures enabling investors to assess the credibility of corporate transition plans. + Ensure that environmental and social indicators relevant to SFDR, EU Climate Benchmark Regulation and CRR Pillar 3 disclosures are disclosed by in-scope companies on a mandatory basis. + Require explanations as to why certain sustainability topics are not considered material for a company. + Reconsider the optional nature of (i) own workforce disclosures on non-employees; and (ii) biodiversity transition plans.
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Response to Initiative on EU taxonomy - environmental objective

2 May 2023

The taxonomy is meant to support the European transition to a sustainable economy, so any activity that will speed up this transition significantly should be acknowledged right away, as a guide and target for companies that wish to pursue a transition towards this science-based platinum standard that the taxonomy should be. Sector-specific pathways and effective transition road maps are only possible if political leadership provides clarity with respect to the end-goal that also they themselves commit to. This leadership must give priority to the sectors that make most difference for a sustainable economy: energy, transport, construction, agriculture & food. That implies that activities that are a major part of the solution to a green economy should be included in the green taxonomy without delay, with very strict conditions. Agriculture and Forestry, NACE codes A01.1, 01.2, 01.3, and A02., should have been included now on the basis of the recommendations of the Sustainable Finance Expert Group, especially in the biodiversity chapter, as increasing biodiversity will support climate change mitigation. At least straightforward conditions like the following should apply: - No use of pesticides and fertilizers - Yearly crop rotation in case of agriculture - Net-zero carbon emissions - A water use and protection management plan in accordance with Directive 2000/60/EC - Or an EU-label for organic agriculture as meant in EU Regulation 834/2007 Also, the baseline of human rights as depicted by the United Nations are clear and could have been included in the sustainable taxonomy. Furthermore, we call upon the European Commission to follow up the Platforms social taxonomy report with urgency, as we are convinced that a sustainable economy is impossible if social impact is ignored. Finally, a green taxonomy must guarantee no harm to the environment. In a transition category, an amber category in the taxonomy, the reduction of harm should be focus. But as long as theres harm done (emissions, pesticides, fertilizers, loss of biodiversity), these activities can never be called green, so the separate category of transition, amber, should be clear and different from green. This also implies that activities should be out of the taxonomy if they are known to significantly harm the environment. We regard the following activities never compatible with a green taxonomy and they should be deleted from this delegated act: - Aviation (NACE code C30.3) - Nuclear energy and gas combustion (NACE codes B, D35 and F42) - Any activity that includes single use oil-based plastic, as its in conflict with Directive 2019/904 (NACE code 22.22 Manufacture of plastic packing goods) - End of pipe solutions, as they imply a process that was not sustainable in the first place which created waste or pollution; for example, collecting hazardous waste is important, but not green, as we want to achieve a world where hazardous waste is not generated in the first place (NACE code E38)
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

9 Jun 2022 · Sustainability in CRR/CRD (staff level)

Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

21 Dec 2021

1. Floors strengthen a diverse banking system. We have been looking forward to the final implementation of Basel III, especially the implementation of the floors. It would protect the financial system against a race to the bottom; the diversity in the banking landscape of large and small players, various banking business models and most of the banks using the standardised approach. It would also protect corporates and citizens against a too high debt burden which was able due to unlimited use of collateral. But we would have welcomed a much faster implementation of this protection than the proposed phase in. We will support the supervisory community in their request for quicker implementation of the floors. 2. With respect to sustainable finance, we are pleased to see that the supervisors’ interpretation of their pillar 2 powers is made explicit. The explicit power to require individual banks to have their internal sustainability checks and balances in order and the threat of an add on in case of insufficient processes in this respect, will force those banks that lag behind to speed up their management of the sustainability impact of what they finance. The additional stress test requirements, and the new horizon of 10 years, will also help ensure that banks know the impact of what they finance. We agree with the European Commission that impact doesn’t discriminate against size, and all finance has an impact, so all banks must disclose their ESG impact and have their internal checks of impact in order. 3. Longer term prudential considerations are, as explained by the ECB, especially necessary as we note that longer term climate-related risk is in many respects of a different nature than the relatively predictable credit risk. After all, humans’ capability to assess possible damage in a forward-looking way is limited, as well their ability to estimate the size of the potential damage that an individual incident could lead to. In fact, we are of the opinion that climate risk can be of such a devastating nature that the only way to mitigate it in a credible way is to put our maximum effort into prevention by ensuring that the financial industry uses its investing capability sustainably. Moreover, the transition towards a sustainable economy comes with opportunities just as much as it comes with risks. The issues that can lead to sustainability risks on the one hand open up opportunities for adapting business models on the other, which in their turn will result in less transition risk. Risk analyses which recognise the interdependence with opportunities would increase the accuracy of monitoring companies in transition. Therefore, we would have welcomed a confirmation of the ECB’s notion that concentrations in climate risk are building up, and that some banks are more exposed than others, as such more vulnerable to shocks and no longer able to finance their local communities. The only real trigger that will change finance decisions towards more sustainable ones, and as such protect the stability of banks over time, is a change in price. We will thus support explicit pillar 1 requirements with respect to potential stranded assets or a risk-concentration in harmful exposures. We also have sympathy for the NGOs “one-for-one” proposal, i.e. new financing of fossil exposures only with equity, not with entrusted money, in order to protect depositors from their money being used for harmful finance. 4. Also, we will contribute to the debate about farm finance, acknowledge their core function in society to provide us with food and take care of their land and animals in a healthy way, and as such make a distinction in the banking rules between those farms that do take care of their longer term impact and those that don’t. As always, Triodos Bank stands ready with alternative text proposals that do justice to people, planet and prosperity and support banks’ role in financing the real economy in a longer term sustainable way.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Triodos Bank repeats and underlines our strong support for an EU sustainable taxonomy rooted in climate and environmental science. While we recognise that the draft DA has taken into account the recommendations of the Commission’s TEG on the climate taxonomy to a large extent, we would like to voice substantial concerns that the draft DA has ignored or weakened the TEG’s scientific advice for several activities. In addition to these, we strongly support the development of a taxonomy of harmful activities, which is crucial to reliably identify risky sectors and accelerate their transition. Forestry & Agriculture: -SFM entails cutting less than the annual growth -Draft DA would allow short-term rotation below 20 years, which is not climate-neutral due to the carbon released; short-term rotation usually employs the wrong type of trees without considering existing forest, tree structures or biomass -SFM definitions, criteria and indicators would guarantee the maintenance of carbon sequestration -DNSH criteria must exclude harm caused by conversion of carbon-rich soils to forest and promote afforestation with native species -Operations should not qualify if they reduce forests’ carbon sink function, lead to irreversible forest degradation or to biodiversity loss -Protection of existing natural forests, restoring and enriching biodiversity and carbon storage potential must be the default Livestock: -Don’t include livestock activities, unless fully circular organic farms -Livestock in general is highly carbon-intensive, polluting, and strongly linked to deforestation, slowing down the transition to a more sustainable, plant-based diet -For any farm in the taxonomy, include GHG reduction benchmark trajectory Fossil fuels (including gas): Life-cycle emissions of green power generation must be kept below 100g CO2e/kWh and move to net-zero asap -An energy-sector-wide emissions intensity threshold of 100g CO2e life-cycle emissions/kWh for electricity generation, heat production and the co-generation of heat and power is pivotal -Limit of 100g CO2e/kWh rightly ensures that unabated fossil fuelled power generation, including new gas-fired power plants, could not be labelled as sustainable -Threshold should be tightened at least every 5 years, zero-carbon by 2050 may be too late for the planet, we encourage a path to zero asap -Adaptation criteria should be reviewed to reduce loopholes enabling investments in unabated fossil fuels with creative interpretation of the criteria Bioenergy: -Accepting all forest biomass as feedstocks and the use of dedicated cropland is contrary to scientific evidence and unacceptable -Burning wood and crops as feedstock is harmful to the planet -Europe’s carbon sink suffers significant losses due to “increasing economic demand for forest biomass” which is why forest biomass must be excluded as an eligible fuel in the up-coming revision of RED II -Consistently, exclude the use of forest biomass in biofuel and biogas for transport and reverse the inclusion of all biofuels and biogas from feedstocks in Annex IX of the REDII eligible for use in transport -Increase savings threshold at least every 5 years in line with a net-zero emissions trajectory to 2050 Hydrogen: -Exclude hydrogen manufactured with fossil and/or non-renewable power -Upstream emissions (including fugitive methane emissions) must be considered in the methodology used to calculate the life-cycle emissions of hydrogen production Datacenters: -Data centers can only be considered transitional activity, if their GHG emissions are substantially lower than the average of the top 10% performers in this industry, considering the economic lifetime of those assets -Proposed thresholds ignore the necessity of energy savings, which will hamper the EU from achieving carbon-neutrality of this activity by 2030 -DNSH criteria must include harm to the use of land, and as such avoid the deterioration of land and eco-systems as a consequence of building
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Response to Long Term Investment Funds – Review of EU rules

14 Oct 2020

Triodos Bank advocates a revision of the ELTIF regulation which suits the Commission’s Just Transition ambitions. Leveraging public money with private money would enable thousands of projects and SMEs to contribute to a fair and green recovery. To that end, ELTIFs should be expanded to investments that suit the doughnut-criteria, considering social impact and environmental boundaries. The expansion would imply a broader investment base and as such cater for better diversified investment pools. However, given the longer-term character of the investments, ELTIFs should remain available for professional investors only, or for non-professional investors that pass a specific suitability test. For retail investors, a revision of the EUSEF Regulation in a way that incorporates the proven and tested UCITS structure, including reassurance of sufficient liquidity at all times, would be much more suitable. EUSEFs that invest in sustainable enterprises, providing positive social and/or environmental impact, usually non-listed, would meet the growing demand of citizens across the EU for investment vehicles in sustainable causes, while protecting them with sufficient diversification and liquidity. A retail passport for EUSEFs would make more sense, provided that registration procedures are as practical as they are for UCITS. ELTIFs could benefit from public support if embedded in cities’ or regions’ recovery-finance toolkit. Cities or regions could issue ELTIFs and back up the risks of the pool of SMEs financed with it, and as such make the funds more attractive for private investors to join. This construction would leverage public funds with private funds and as such contribute to a just and green recovery.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

6 Jul 2020 · meeting on the European Green Deal

Response to Institutional investors' and asset managers' duties regarding sustainability

20 Jun 2018

We sincerely support the Commission’s initiative to consult upon possible amendments to Regulation 2017/565 resp. Reg. 2017/2359. We appreciate the scope of the amendments, i.e. all investments and all investors. This will enable true choices between sustainable and non-sustainable causes. The proposed amendments would affect millions of investors, especially retail customers, who will have to think about their sustainability demands and wishes. If people are asked questions like “Would you like to invest your money in weapons, drugs and child labour?” this will significantly increase the awareness of the impact of finance. Retail investors should be enabled to invest their money in a more sustainable and conscious way. This would mobilise a lot of capital flow towards sustainable investments as is defined in the Action Plan. It all starts with transparency. Investment firms need to sustain their ESG claims. It would be very helpful if this is done in a harmonised way so that clients are indeed able to compare investment products. Investors, investment entities and banks should be aware of the impact their investment and finance decisions have on society, both positive and negative impact. There is no such thing as neutral financial exposure. Allocating capital (investing or financing) to any economic activity has an impact on staying within or beyond our planetary boundaries and reducing or increasing social inequality and poverty. Triodos Bank believes that to promote human dignity, environmental conservation and quality of life in general, a genuinely responsible approach to business is key, including transparency and using money more consciously. See our impact analyses on www.triodos-im.com<http://www.triodos-im.com The proposal explains ESG considerations from an inclusive point of view. So what activities could be considered in light of social, environmental and governance impact. It doesn’t refer, however, to activities that are excluded for investment. Triodos regards both. Otherwise, again, investment firms will pick out some nice examples of positive impact in the portfolio and at the same time have the opportunity to invest in the worst of the worst in the other part of the portfolio. Clients should also be asked the questions what activities/practices they want to exclude from their investment portfolio on top of the questions what they do want to finance. We suggest the text is balanced for exclusion preferences. If properly defined, the amendments would imply a tremendous leverage for both investors and the banks or asset managers that serve them, as they would induce banks to train their employees and it would regard their entire customer base. The proposed definitions, however, imply a dangerous opportunity for green-washing, which the EU must avoid! By referring to “investments”, the definitions allow banks and asset managers to offer thematic funds that include some of the preferred theme(s), but don’t change the way they select and assess potential investees! To avoid green-washing, the definitions should refer to “criteria”. This would imply that banks and asset managers will have to assess and select all possible investments according to the clients’ ESG preferred criteria. For example, definition 2(7): “(7) ‘ESG preferences’ means a client’s or potential client’s preferences for environmentally sustainable investments, social investments or good governance investments; “ should be amended as “(7) ‘ESG preferences’ means a client’s or potential client’s preferences for environmentally sustainable criteria, social criteria or good governance criteria;” and the same for the other definitions in Article 2. We trust that the Commission will change the definitions such that green-washing will be avoided.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

19 Jan 2018 · sustainable finance