Extension of the 'do no significant harm' principle under the next EU Multiannual Financial Framework

ClientEarth recommends that the European Commission establish a single 'do no significant harm' (DNSH) guidance for the next Multiannual Financial Framework (MFF) to serve as a legally binding minimum requirement for all EU funds. The organization proposes the inclusion of an explicit exclusion list—specifically targeting fossil fuel activities—and suggests linking the guidance to the methodology on environmental harmful subsidies (EHS). To ensure effectiveness, ClientEarth advocates for the application of the precautionary principle, increased transparency in assessments, and the extension of the DNSH principle to EU state aid policy to prevent the shift of harmful spending to national budgets.

• The proposed single DNSH guidance should establish a minimum requirement for all EU funds and sectors, while allowing for additional tailored tools such as checklists or thresholds for specific funds.
• The guidance should include a general list of outright exclusions for activities that unequivocally harm the environment, with fossil fuel funding specifically identified as an item that must be irrevocably excluded.
• ClientEarth suggests that any project or measure qualifying as an environmental harmful subsidy (EHS) under the European Commission's methodology should be deemed non-compliant with the DNSH principle.
• To ensure the DNSH principle is enforceable, it should be an eligibility requirement rather than a horizontal principle, requiring ex-ante demonstration of compliance and verification during implementation, supported by payment suspension or recovery mechanisms.
• The precautionary principle should be integrated into the guidance, meaning projects lacking sufficient scientific evidence or those with potential long-term harmful lock-in effects should not receive funding.
• To prevent the risk of increased harmful public spending within national budgets, the DNSH principle should be applied horizontally across EU state aid policy.

APA

ClientEarth (2024). Extension of the 'do no significant harm' principle under the next EU Multiannual Financial Framework. https://www.clientearth.org/media/csvogxse/clientearth-reply-to-call-for-evidence-guidance-on-applying-the-dnsh-principle.pdf

Chicago

ClientEarth. Extension of the 'do no significant harm' principle under the next EU Multiannual Financial Framework. 2024. https://www.clientearth.org/media/csvogxse/clientearth-reply-to-call-for-evidence-guidance-on-applying-the-dnsh-principle.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Extension of the 'do no significant harm' principle under the next EU Multiannual Financial Framework |date=May 2024 |url=https://www.clientearth.org/media/csvogxse/clientearth-reply-to-call-for-evidence-guidance-on-applying-the-dnsh-principle.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2024extension, author = {{ClientEarth}}, title = {{Extension of the 'do no significant harm' principle under the next EU Multiannual Financial Framework}}, publisher = {ClientEarth}, year = {2024}, month = may, url = {https://www.clientearth.org/media/csvogxse/clientearth-reply-to-call-for-evidence-guidance-on-applying-the-dnsh-principle.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }