While the EACB broadly supports the proposal, we wish to raise specific issues (MPS, EPC, data) following the publication of the co-legislators’ respective positions, which in our view could hinder the goals of the Directive. We argue in favour of voluntary mechanisms (Mortgage Portfolio Standards, pay-as-you-save financial schemes) and ask for energy performance certificates that are harmonised throughout the EU. The financial industry also needs sufficient access to relevant data for the framework to be efficient.
The Commission’s initiative to recast the EPBD is extremely welcome by EU cooperative banks as it will enable them to support the transition to energy-efficient buildings. As access to private finance is a key tenet of the new European renovation wave, the EACB firmly believes that green buildings and deep renovations should be financed by appropriate loans where compatible with households’ ability to repay, in order to achieve the necessary climate goals.
There remains a dilemma for cooperative banks in particular as they are more exposed to remote areas and less affluent clients. Their business model is typically more oriented towards mortgage financing than other type of banks. Under voluntary MPS, it should be possible to account for the financing of lower energy performance properties, where a proper renovation plan is set for future improvement. Under mandatory MPS, cooperative banks would either comply at the risk of withdrawing support to local communities and less affluent customers, or they would keep supporting poorer households and financing more challenging buildings at the risk of not being able to comply with MPS or even banking prudential metrics.
As regards Energy Performance Certificates, we would welcome a simpler system for obtaining energy classification of buildings (including in particular for small houses and old buildings).
Finally, in order to ensure that financial institutions’ activities are based on data that is accurate and complete, the Directive should ensure that they can access such data in a machine readable format which ensures a feasible IT operability in order to include such information into banks’ existing datasets.