The implementation of the 'Do No Significant Harm' principle in selected EU instruments : a comparative analysis

In its more common formulation in the European Union (EU) policy context, the Do No Significant Harm principle aims to ensure that EU policies and programmes do not have a negative impact on and environmental objectives. By doing this, the principle has transformed the from the European Green Deal into a reality applied by different EU initiatives. This study analyses the application of the DNSH principle in six EU instruments which have pioneered the use of the DNSH principle to integrate climate and environmental objectives in private finance and public funding: 1) the EU Taxonomy for sustainable activities; 2) the Recovery and Resilience Facility; 3) the European Regional Development Fund; 4) the Cohesion Fund; 5) the Just Transition Fund; and 6) the InvestEU Fund. The analysis maps the divergences in the way the DNSH principle is implemented across these EU instruments, identifying reasons that help to explain them. It also highlights existing interlinkages and commonalities in the application of the principle as well as the potential to build on the knowledge gained to develop common tools that could guide its implementation across EU instruments. Additionally, the implementation of the DNSH principle is starting to be applied in EU instruments extending beyond the current 2021-2027 policy cycle. In this context, the study suggests additional actions to take advantage of existing opportunities and to minimise potential risks.