UIPI responds to consultations on the EU taxonomy review of climate and environmental delegated acts
In December 2025, UIPI submitted its feedback to the European Commission’s call for evidence on Sustainable investment – review of the EU taxonomy environmental and climate delegated acts.
The EU Taxonomy is the EU’s system for defining which economic activities are environmentally sustainable. For real estate, it sets criteria for construction, renovation and building ownership. The climate and environmental delegated acts specify the technical screening criteria for activities contributing to the EU’s climate and environmental objectives.These delegated acts are under review because some criteria have proven too complex, unclear, and misaligned with updated legislation (e.g. the revised EPBD). The Commission aims to simplify and clarify them to ensure proportionality and make them more practical for the financial sector. Through this consultation, stakeholders were invited to identify criteria that are difficult to comply with, inconsistencies with existing EU law, and offer guidance on how to make rules more practical.
UIPI welcomes this review and supports the Commission’s intention to improve usability and legal certainty. In its reply, UIPI highlighted several priorities to help make the taxonomy an effective tool for accelerating building decarbonisation, including:
- Better recognition of renovation. Renovation is key to decarbonisation and criterions should allow staged and cumulative improvements, recognise renovation revenues as sustainable, and replace “major renovation” with “deep renovation” for clarity.
- Simplification of “do no significant harm” (DNSH) requirements. DNSH criteria are partially duplicative and can be consolidated. They should also encourage the use of recognised and locally available building certifications, including digital building passports and other evidence-based instruments to demonstrate compliance.
- Ensure full alignment with the revised EPBD by updating outdated definitions and safeguarding that new requirements do not duplicate EPBD obligations.
- Improved Acquisition and Ownership treatment. Criteria should reflect real investment cycles and allow transitional “green” status for buildings on a decarbonisation pathway.