The HLEG on Sustainable Finance has invited all citizens to provide feedback to their Interim report via a non-technical questionnaire by Sept. 20th. Early feedback received by Sept. 6th will contribute to next HLEG discussion on Sept. 11th. 



In this post we publish the replies from the Global Climate Forum, member of the DOLFINS Consortium. The future of Europe depends on Sustainable Finance. Citizens have the unique opportunity to contribute to the debate at an early stage, well before the policy proposal is issued. The FET-funded project DOLFINS is supporting this effort. The contributions of DOLFINS members are published in a series of blog posts on the simpolproject platform and on our twitter profile .


Question 1. From your constituency’s point of view, what is the most important issue that needs to be addressed to move towards sustainable finance? (sustainable finance being understood as improving the contribution of finance to long-term sustainable and inclusive growth, as well as strengthening financial stability by considering material environmental, social and governance factors).

Reply: A credible and coherent climate policy, which coordinates investors’ expectations, is the most important factor for shifting more private capital towards sustainable finance. This would result in reduced risks for sustainable investments, which would attract more investors, leading to a positive feedback loop.

Question 2. What do you think such an EU taxonomy for sustainable assets and financial products should include?

Reply: It is very important for the taxonomy to be transparent and to formulate clear and standardised criteria.

Question 3. What considerations should the EU keep in mind when establishing a European standard and label for green bonds and other sustainable assets? How can the EU ensure high-quality standards and labels that avoid misuse/green-washing?

Reply: Third-party verification of all green bonds and other green assets is an important measure. Verifiers should follow the same guidelines, and should be registered and audited by the EU on a regular basis. When establishing such a system, the experiences from other verification systems (e.g. Clean Development Mechanism, Joint Implementation) and third party verifiers of green bonds (e.g. Cicero, Sustainalytics) should be taken into account.

Question 4. What key services do you think an entity like “Sustainable Infrastructure Europe” should provide, more specifically in terms of advisory services and connecting public authorities with private investors?


  • Connect public authorities with investors to identify projects and help to bundle and standardize them (especially in the area of Energy Efficiency and especially in Central and Eastern Europe).
  • Provide a detailed sustainability assessment of all infrastructure projects and to proactively develop improvements (to maximize the sustainability rating of these projects).
  • Help ensure the sustainability of projects (including economic sustainability) by closely monitoring project progress. Ensure benefit for the general public.
  • Provide a pipeline in line with the political goals of the EU concerning climate and energy, investment, and financial stability.

Question 5. It is frequently stated that the inherent short-termism in finance, especially financial markets, represents a distraction from, or even obstacle to, a long-term orientation in economic decision-making, including investments that are essential for sustainability. Do you agree with this statement?

Reply: Yes.

Question 6. What key levers do you think the EU could use to best align the investment and analyst community with long-term sustainability considerations in the real economy?

Reply: Periodic mandatory and standardised disclosure of potential climate related risks and sustainability/ ESG are considered most important.

Question 7. How can the EU best create a strong and visible pipeline of sustainable investment projects ready for investment at scale?

Reply: For a pipeline of sustainable investment projects, the following is proposed:

  • EIB and EBRD should concentrate on helping investors finance projects, e.g. by evaluating them/standardizing/providing guarantees.
  • Public banks could require private co-financing (by local banks or other investors) for such projects, i.e. via the EEEF or other funds.
  • A process like EFSI for sustainable investment projects should be established, thus creating a visible pipeline and providing guarantees.
  • Support schemes for Renewables and Energy Efficiency in European countries that lack such schemes should be developed/improved.
  • Active sourcing of projects in EU countries that are currently underrepresented in such pipelines is important.

Question 8. What are some of the most effective ways to encourage credit rating agencies to take into consideration ESG factors and/or long-term risk factors? Please choose 1 option from the list below.

  • Create a European credit rating agency designed to track long-term sustainability risks
  • Require all credit rating agencies to disclose whether and how they consider TCFD-related information in their credit ratings
  • Require all credit rating agencies to include ESG factors as part of their rating
  • All of the above
  • Other

Reply: Other. Require all credit rating agencies to include ESG factors as part of their rating.

Question 9. What would be the best way to involve banks more strongly on sustainability, particularly through long-term lending and project finance?


  • Adapt risk assessment by taking into account increased experience and track records for green and low-carbon assets (making sustainable investments more attractive).
  • Include climate-related risks into risk assessments (making unsustainable investments less attractive).

Question 10. What would be the best way to involve insurers more strongly on sustainability, particularly through long-term investment?

Reply: To involve insurers in sustainability, we consider most important:

  • Adapt risk assessment by taking into account increased experience and track records for green and low-carbon assets (making sustainable investments more attractive).
  • Include climate-related risks into risk assessments (making unsustainable investments less attractive).
  • Standardize and bundle energy efficiency projects to make it easier to invest (while ensuring certain investment quality standards).

Question 11. What do you think should be the priority when mobilising private capital for social dimensions of sustainable development?

Reply: It is important to ensure that it is beneficial for society and does not only lead to enhancement of private revenues.

Question 12. Do you have any comments on the policy recommendations or policy areas mentioned in the Interim Report but not mentioned in this survey?

Reply: More discussions about the role of major indices (like Dow and DAX) in investment decisions could be beneficial. These indices are crucial benchmarks, and often represent many carbon intensive companies (and thus have a much greater carbon footprint than e.g. the economies of the countries they are based in). Strengthening green indices such as the Dow Jones Sustainability Indices could be a measure to make green investment alternatives more visible.

The SIMPOL Project is currently funded by the H2020 European grant DOLFINS (no. 640772) in the Global Systems Science area of the Future Emerging Technologies program.