Brussels workshop: new DNSH guidelines to be simpler and more practical

DNSH: less paperwork, more practice

Workshop participants unanimously stressed that DNSH should not be merely a reporting obligation or an excessive administrative burden. Its practical role – supporting sustainable investment preparation and implementation – remains a priority.

The European Commission has announced that future guidelines will:

• simpler and clearer,
• tailored to the scale and nature of the projects,
• results-oriented.

Among the key demands were:

• Proportionality – limiting requirements to small projects with low environmental impact,
• Clarity of rules – understandable guidelines for administration and beneficiaries,
• A practical approach to documentation – without duplication of obligations under EU and national law,
• Exclusion list – a catalog of activities that do not require a DNSH assessment.

Better link to environmental impact assessment

One of the most important topics was the relationship between DNSH and environmental impact assessment (EIA). The need for greater consistency between the two processes and reducing duplication of requirements was pointed out.

For projects covered by the EIA Directive:

• obtaining an environmental decision should, in principle, confirm compliance with DNSH,
• responsibility for the assessment should remain with the relevant environmental authorities.

For smaller projects that do not require an EIA, the use of national regulations and technical standards was considered sufficient.

Climate change adaptation and infrastructure resilience

Great emphasis was placed on:

• Development ofnature-based solutions (nature-based solutions),
• Strengthening the resilience by design approach, i.e. taking climate resilience into account at the design stage of an investment.

Practical challenges and proposals for change

The discussion also covered specific problems raised by institutions and beneficiaries, including:

• assessing compliance in a circular economy,
• confirming the application of best available techniques (BAT),
• The scope of the required documentation and monitoring of project implementation.

It also pointed out the need to take into account new EU regulations, such as:

• Critical Raw Materials Act,
• Nature Restoration Law.

Flexibility and national approach

It was stressed that the future DNSH framework should take into account the specifics of member states. Among the solutions considered were:

• DNSH national focal points,
• Knowledge sharing networks between institutions,
• The possibility of creating complementary national criteria.

What’s next?

The European Commission has announced the publication of draft new DNSH guidelines in July or August this year. The document is expected to build on past experience and focus on simplifying the rules and making them more useful for institutions and beneficiaries.