Guidance on applying the ‘do no significant harm’ principle under the 2028-2034 MFF

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The document argues that the DNSH principle should be a binding eligibility requirement for EU funding rather than a general guideline, ensuring that no activity funded by the EU budget causes significant harm to any of the six environmental objectives. It calls for a strict interpretation of derogations, the creation of an explicit exclusion list—specifically including fossil fuels—and the implementation of transparent, independent assessment procedures to prevent the 'watering down' of environmental standards.

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  • The DNSH principle serves as a practical tool to operationalise the integration principle of environmental protection into EU policies, acting as a 'silo-breaker' that prevents progress in one environmental area, such as climate mitigation, from occurring at the expense of others like biodiversity or water resilience.
  • ClientEarth recommends that compliance with the DNSH principle be established as a mandatory eligibility requirement for accessing EU funding, with verification occurring both ex-ante and during the implementation phase, supported by mechanisms for the suspension or recovery of payments in cases of non-compliance.
  • The document argues for a strict and narrow interpretation of derogations from the DNSH principle. It specifically warns that 'security activities' must not be used as a justification for funding fossil fuels and that 'overriding public interest' should not exempt projects from DNSH assessments since such projects are by definition harmful.

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APA
ClientEarth (2026). Guidance on applying the ‘do no significant harm’ principle under the 2028-2034 MFF. https://www.clientearth.org/media/dmljjwhl/clientearth-call-for-evidence-on-dnsh-guidance-april-2026.pdf
Chicago
ClientEarth. Guidance on applying the ‘do no significant harm’ principle under the 2028-2034 MFF. 2026. https://www.clientearth.org/media/dmljjwhl/clientearth-call-for-evidence-on-dnsh-guidance-april-2026.pdf.
Wikipedia
{{cite press release |author=ClientEarth |title=Guidance on applying the ‘do no significant harm’ principle under the 2028-2034 MFF |date=April 2026 |url=https://www.clientearth.org/media/dmljjwhl/clientearth-call-for-evidence-on-dnsh-guidance-april-2026.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{clientearth2026guidance, author = {{ClientEarth}}, title = {{Guidance on applying the ‘do no significant harm’ principle under the 2028-2034 MFF}}, publisher = {ClientEarth}, year = {2026}, month = apr, url = {https://www.clientearth.org/media/dmljjwhl/clientearth-call-for-evidence-on-dnsh-guidance-april-2026.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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