ESA Joint Committee · sfdr-78 Final

Can taxonomy-aligned activities or PAI impacts from green bonds (or other specific project financing instruments like social bonds) be calculated for the projects they finance rather than taxonomy-ali

Regulation
SFDR
Answered
2022-11-17
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

Can taxonomy-aligned activities or PAI impacts from green bonds (or other specific project financing instruments like social bonds) be calculated for the projects they finance rather than taxonomy-aligned activities of or impacts arising from the issuer as a whole?

Answer

Taxonomy-alignment For the purpose of calculating the proportion of taxonomy-aligned assets contributing to taxonomy- aligned economic activities, only the projects financed by green bonds under the future EU Green Bond Standard and other green bonds (the proportion of their value that corresponds to the share of the proceeds of those bonds used for environmentally sustainable economic activities) should be considered. As stated in Article 17(1)(b) of the Delegated Regulation, for its taxonomy-alignment KPI, a financial market participant can count an investment in a green bond up to the level of taxonomy-aligned activities the use of proceeds goes towards. The financial market participant should not take into account the issuer of such instruments for the purpose of the taxonomy-alignment KPI of the financial product. PAI disclosure Furthermore, with regard to the disclosure of principal adverse impacts under Article 4 SFDR, Section II and Annex I of the Delegated Regulation (and where financial products use the indicators provided in Annex I for the purpose of their Article 7 SFDR disclosures) and to demonstrate that a project meets the DNSH condition of the definition of sustainable investment set out in Article 2(17) SFDR, financial market participants could adjust the metrics to reflect the fact that project financing bonds finance only specific activities and not the entire undertaking. Some PAI indicators in Table 1 of Annex I of the Delegated Regulation could be applied at “project” level and not company level where the investment is in a security that finances a specific project rather than the issuer issuing the security, for instance GHG emissions (Table 1, Indicator 1), land artificialisation (Table 2, Indicator 18) or rate of accidents (Table 3, Indicator 2), while some other PAI indicators could still be applied at company level such as the unadjusted gender pay gap (table 1, indicator 12).

This Q&A is published by ESA Joint Committee (EBA, ESMA, EIOPA) and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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