In view of the new EU legislature and upcoming workstreams in the field of sustainable finance and consumer policy, the EACB has been reflecting on a number of potential policy developments affecting the provision of green loans and mortgages to actors in the real economy. Based on the EBA’s Opinion and report published last year, containing advice to for the Commission, EU cooperative banks have formulated a number of considerations on the existing regulatory framework and the possibility of creating a dedicated EU Label for green loans and mortgages.
While we welcome the EBA’s contribution to the realization of ambitious EU environmental and transition goals, we would take this opportunity to underscore elements from a practical perspective on green loans and mortgages in Europe, in the context of the current sustainable finance framework, the various initiatives it encompasses, and the foreseen activities of the incoming legislature.
We support that EU sustainable finance policy should always rest on established scientific criteria. However, clarifications are needed in applying the Taxonomy, in particular when it comes to SMEs and households. In addition, there is a crucial need for the regulatory framework to properly account for and drive transition.
Crucially, the regulatory framework applicable to banks should be coherent: the many initiatives coming in to play (Mortgage Credit, Consumer Credit, Energy Performance of Buildings, Capital Requirements, and so on) should be aligned and coherent in order to be effective.
Finally, we maintain that commercial policies on green loans should remain at the discretion of banking institutions, each of which maintains its own risk and business policies.
EU Cooperative banks remain committed to supporting the green transition of the EU economy; as such, we welcome regulatory alignment, streamlining, and a generally practical approach.