Performance Regulation: Fixing the details

The document argues that the proposed 35% environmental and climate spending target is insufficient and should be increased to 50%, while removing exemptions for defence and security spending. It identifies significant 'greenwashing' risks in Annex I, specifically regarding targeted support to farmers' income, military mobility, and critical raw materials extraction. The briefing provides a detailed technical reference document proposing changes to over 100 intervention fields, including the deletion of activities that violate the 'Do no significant harm' (DNSH) principle, such as hydropower, nuclear fission, and airport capacity expansion.

• The proposed 35% environmental and climate spending target for the next EU budget is considered insufficient to meet 2030 and 2040 climate and nature targets, and the authors call for it to be increased to 50%.
• Exemptions for defence and security spending from the calculation base of the spending target undermine its credibility and could reduce the effective target from 35% to between 31.2% and 33.25%.
• Certain intervention fields in Annex I pose a high risk of systemic greenwashing; specifically, targeted support to farmers' income, military mobility, and critical raw materials extraction could lead to an estimated 7.61% of the EU budget being misclassified as green.
• The authors recommend the complete removal of several intervention fields from the budget due to violations of the 'Do no significant harm' (DNSH) principle, including hydropower, nuclear fission, low-carbon hydrogen production, and airport capacity expansion.
• The briefing argues for the reintroduction of separate tracking for biodiversity expenditure to ensure the EU meets its reporting obligations under the global Kunming-Montreal Biodiversity Framework.
• The document identifies specific technical flaws in tagging, such as the 100% climate tagging for carbon capture and storage (CCS) and biofuels, arguing these should be 0% due to risks of carbon leakage, fossil fuel lock-in, and negative impacts on carbon sinks.

APA

ClientEarth (n.d.). Performance Regulation: Fixing the details. https://www.clientearth.org/media/35uhmogc/performance-regulation_briefingplustechnical-reference-document.pdf

Chicago

ClientEarth. Performance Regulation: Fixing the details. n.d. https://www.clientearth.org/media/35uhmogc/performance-regulation_briefingplustechnical-reference-document.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Performance Regulation: Fixing the details |url=https://www.clientearth.org/media/35uhmogc/performance-regulation_briefingplustechnical-reference-document.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearthndperformance, author = {{ClientEarth}}, title = {{Performance Regulation: Fixing the details}}, institution = {ClientEarth}, url = {https://www.clientearth.org/media/35uhmogc/performance-regulation_briefingplustechnical-reference-document.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }