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1.1 The TEG identifies five key barriers to the development of the green bond market (see Section 2.2 of the report of the Technical Expert Group subgroup on Green Bond Standard (the report)). On a scale from 1 to 5, please express your view as to the importance of each of these barriers (1 indicating the lowest importance): : a) Absence of clear economic benefits associated with issuance of green bonds ([ID86])
1.1 The TEG identifies five key barriers to the development of the green bond market (see Section 2.2 of the report of the Technical Expert Group subgroup on Green Bond Standard (the report)). On a scale from 1 to 5, please express your view as to the importance of each of these barriers (1 indicating the lowest importance): : b) Issuers’ concerns with reputational risks and green definitions ([ID87])
1.1 The TEG identifies five key barriers to the development of the green bond market (see Section 2.2 of the report of the Technical Expert Group subgroup on Green Bond Standard (the report)). On a scale from 1 to 5, please express your view as to the importance of each of these barriers (1 indicating the lowest importance): : c) Complex and potentially costly external review procedures ([ID88])
1.1 The TEG identifies five key barriers to the development of the green bond market (see Section 2.2 of the report of the Technical Expert Group subgroup on Green Bond Standard (the report)). On a scale from 1 to 5, please express your view as to the importance of each of these barriers (1 indicating the lowest importance): : d) Uncertainty with regards the type of assets and expenditures that can be financed by green bonds ([ID89])
1.1 The TEG identifies five key barriers to the development of the green bond market (see Section 2.2 of the report of the Technical Expert Group subgroup on Green Bond Standard (the report)). On a scale from 1 to 5, please express your view as to the importance of each of these barriers (1 indicating the lowest importance): : e) Lack of clarity with regards to the practice for the tracking of proceeds ([ID90])
1.2 Have you identified other barriers to the development of the green bond market, in addition the ones listed above? Please comment as appropriate:([ID3])
Recommendations 1-4: Please express your agreement with the proposed recommendations by ticking the yes/no box: : Recommendation 1: Create a voluntary EU Green Bond Standard ([ID13])
Recommendations 1-4: Please express your agreement with the proposed recommendations by ticking the yes/no box: : Recommendation 2: Monitor impact and consider further supporting action including possible legislation after an estimated period of 3 years ([ID14])
Recommendations 1-4: Please express your agreement with the proposed recommendations by ticking the yes/no box: : Recommendation 3: Develop a legislative proposal for a centralised accreditation regime for external green bond verifiers to be potentially operated by ESMA ([ID17])
Recommendations 1-4: Please express your agreement with the proposed recommendations by ticking the yes/no box: : Recommendation 4: Set up a market-based voluntary Accreditation Committee for external verifiers of green bonds for a transition period ([ID18])
Please add any comments to your replies on recommendations 1 to 4, as appropriate:([ID169])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 5: Encourage investors (in particular institutional investors) to adopt the requirements of the EU-GBS and actively communicate their commitment ([ID57])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 6: Adopt an ambitious disclosure regime for institutional investors ([ID58])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 7: Consider promoting greening the financial system by expressing and implementing a preference for EU green bonds ([ID59])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 8: Develop credit enhancement guarantees for sub-investment grade green bonds ([ID83])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 9: Encourage all types of European issuers to issuing their future green bonds in compliance with the requirements of the EU GBS ([ID95])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 10: Set up a grant scheme to off-set the additional cost of external verification for issuers ([ID97])
Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : Recommendation 11: Promote adoption of the EU Green Bond Standard through the EU eco-label for financial products ([ID98])
Please add any comments to your replies on recommendations 5 to 11, as appropriate::([ID205])
3.1 The TEG proposes that the proceeds from EU green bonds be allocated to green projects (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report). Do you agree that green projects may include the following items? : a) eligible green assets including physical assets and financial assets such as loans; ([ID102])
3.1 The TEG proposes that the proceeds from EU green bonds be allocated to green projects (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report). Do you agree that green projects may include the following items? : b) the share of the working capital that can reasonably be attributed to the operation of such eligible, tangible or intangible, green assets; ([ID103])
3.1 The TEG proposes that the proceeds from EU green bonds be allocated to green projects (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report). Do you agree that green projects may include the following items? : c) eligible green operating expenditures related to improving or maintaining the value of eligible assets; ([ID104])
3.2 Please add any comments to your replies to question 3.1, as appropriate:([ID105])
4.1 The TEG proposes (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report) that eligible green expenditures qualify for refinancing with a maximum three years look-back period before the issuance year of the EU green bond, while eligible green asset qualify with no maximum look-back period. Do you agree that a maximum look-back period be imposed with regard to the refinancing of eligible green expenditures? : a) Do you agree that a maximum look-back period be imposed with regard to the refinancing of eligible green expenditures? ([ID118])
4.1 The TEG proposes (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report) that eligible green expenditures qualify for refinancing with a maximum three years look-back period before the issuance year of the EU green bond, while eligible green asset qualify with no maximum look-back period. Do you agree that a maximum look-back period be imposed with regard to the refinancing of eligible green expenditures? : b) Do you agree that a no maximum look-back period be imposed with regard to the refinancing of eligible green assets? ([ID119])
4.2 If any of your answers to question 4.1 is no, what is the maximum look-back period you would propose for reference in the EU Green Bond Standard? Please explain your view:([ID122])
5.1 The TEG proposes (Section 3.3.1 of the report) that in cases where: the Taxonomy is not yet in force; the technical criteria are not yet available; or when technical criteria are considered not directly applicable due to the innovative nature, complexity, and/or the location of the green projects, the issuer be allowed to rely on the fundamentals of the Taxonomy to verify the alignment of their green projects with the Taxonomy. Do you agree with this approach?([ID107])
5.2 Please add any comments to your reply to question 5.1, as appropriate:([ID113])
6.1 The TEG proposes (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report)) that the issuer produces a green bond Framework (GBF) which confirms the voluntary alignment of green bonds with the EU Green Bond Standard and provides details on key aspects of the use of proceeds and the issuer’s green bond strategy and processes. Do you agree with the envisaged content and role of the GBF?([ID130])
6.2 Please add any comments to your reply to question 6.1, as appropriate:([ID131])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : a) Statement of compliance with the EU Green Bond Standard ([ID125])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : b) Amount allocated to each green projects or green project categories; with the classification of such projects according to the EU Taxonomy and/or to EU environmental objectives ([ID126])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : c) Nature of green projects (assets, capital expenditures, operating expenditures, etc.) ([ID132])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : d) Share between green project financing and refinancing ([ID133])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : e) Share of green projects financed by the issuer (if applicable) ([ID134])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : f) Actual or estimated impact of the green projects based on metrics outlined in the GBF ([ID135])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : g) Regional distribution of green projects ([ID136])
7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation. Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement): : h) Green bond ratio ([ID138])
7.2 Please add any comments to your replies to question 7.1, as appropriate:([ID139])
8.1 The TEG proposes (Section 4.4 of Annex 1: draft model of the EU green bond standard to the report) that the issuer appoints External Reviewers to verify both: before or at issuance, the issuer’s GBF, AND; after allocation of proceeds, the EU green bond allocations and the actual or estimated impact reporting provided by the issuer. Do you agree with this approach to verification as proposed by the TEG?([ID161])
8.2 Please add any comments to your reply to question 8, as appropriate:([ID141])
9. The TEG puts forward (Section 5 of the report) for consideration by the European Commission, a series of proposals for incentives to support the EU green bond market. Do you have any comment on the incentives stated in the Section 5.1?([ID140])
10.1 Some of these proposals stated in 5.2 pose challenges to their implementation – requiring the engagement of several authorities, the acquisition of new competencies and involving prolonged timelines. These proposals will require further analysis by the TEG as well as outreach and feedback from a broad range of stakeholders. Please express your view on the potential effectiveness of such proposals using the scale from 1 to 5, with 1 indicating no effectiveness: : a) Tax incentives at issuer or investor level (including accelerated depreciation for assets financed by green bonds and loans) ([ID148])
10.1 Some of these proposals stated in 5.2 pose challenges to their implementation – requiring the engagement of several authorities, the acquisition of new competencies and involving prolonged timelines. These proposals will require further analysis by the TEG as well as outreach and feedback from a broad range of stakeholders. Please express your view on the potential effectiveness of such proposals using the scale from 1 to 5, with 1 indicating no effectiveness: : b) Favoring EU green bonds in relevant financial sector regulation and prudential rules ([ID149])
10.2 Have you considered any other proposals for incentives in addition to the ones outlined by the TEG in Section 5 of the report? Please comment as appropriate:([ID150])
11.1 The objective of the EU GBS is to support the scaling up of the green bond market in the EU, while at the same time safeguarding the integrity of this market. Through which of the means is the EU GBS likely / unlikely achieve to this objective? Please express your view using the scale from 1 to 5, with 1 indicating unlikely. : a) Alignment of eligible green projects with the EU Taxonomy – expected to reduce uncertainty over greenness and provide clear guidance ([ID162])
11.1 The objective of the EU GBS is to support the scaling up of the green bond market in the EU, while at the same time safeguarding the integrity of this market. Through which of the means is the EU GBS likely / unlikely achieve to this objective? Please express your view using the scale from 1 to 5, with 1 indicating unlikely. : b) Clarification with regards to some key elements involved in green bond issuance: tracking of proceeds, nature of eligible assets / expenditures – expected to reduce uncertainty and provide clear guidance ([ID163])
11.1 The objective of the EU GBS is to support the scaling up of the green bond market in the EU, while at the same time safeguarding the integrity of this market. Through which of the means is the EU GBS likely / unlikely achieve to this objective? Please express your view using the scale from 1 to 5, with 1 indicating unlikely. : c) Requirement for the publication of issuer’s GBF and for allocation- and impact reporting – expected to increase transparency and promote standardisation in provision of information ([ID164])
11.1 The objective of the EU GBS is to support the scaling up of the green bond market in the EU, while at the same time safeguarding the integrity of this market. Through which of the means is the EU GBS likely / unlikely achieve to this objective? Please express your view using the scale from 1 to 5, with 1 indicating unlikely. : d) Mandatory external review (and accreditation of reviewers – expected to support reliability of information, market integrity, and promote standardisation in provision of information ([ID165])
11.2 Please add any comments to your replies to question 11, as appropriate:([ID166])
12. Are there any other relevant issues that you would like to bring to the attention of the TEG: Please comment as appropriate:([ID168])
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:(file-upload)
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Please specify under which capacity has your organisation been active in the green bond market:
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Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
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1.1 The TEG identifies five key barriers to the development of the green bond market (see Section 2.2 of the report of the Technical Expert Group subgroup on Green Bond Standard (the report)).

On a scale from 1 to 5, please express your view as to the importance of each of these barriers (1 indicating the lowest importance):

a) Absence of clear economic benefits associated with issuance of green bonds

b) Issuers’ concerns with reputational risks and green definitions

c) Complex and potentially costly external review procedures

d) Uncertainty with regards the type of assets and expenditures that can be financed by green bonds

e) Lack of clarity with regards to the practice for the tracking of proceeds

1.2 Have you identified other barriers to the development of the green bond market, in addition the ones listed above? Please comment as appropriate:

Recommendations 1-4: Please express your agreement with the proposed recommendations by ticking the yes/no box:

Recommendation 1: Create a voluntary EU Green Bond Standard

Recommendation 2: Monitor impact and consider further supporting action including possible legislation after an estimated period of 3 years

Recommendation 3: Develop a legislative proposal for a centralised accreditation regime for external green bond verifiers to be potentially operated by ESMA

Recommendation 4: Set up a market-based voluntary Accreditation Committee for external verifiers of green bonds for a transition period

Please add any comments to your replies on recommendations 1 to 4, as appropriate:

Recommendations 5-11: Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement):

Recommendation 5: Encourage investors (in particular institutional investors) to adopt the requirements of the EU-GBS and actively communicate their commitment

Recommendation 6: Adopt an ambitious disclosure regime for institutional investors

Recommendation 7: Consider promoting greening the financial system by expressing and implementing a preference for EU green bonds

Recommendation 8: Develop credit enhancement guarantees for sub-investment grade green bonds

Recommendation 9: Encourage all types of European issuers to issuing their future green bonds in compliance with the requirements of the EU GBS

Recommendation 10: Set up a grant scheme to off-set the additional cost of external verification for issuers

Recommendation 11: Promote adoption of the EU Green Bond Standard through the EU eco-label for financial products

Please add any comments to your replies on recommendations 5 to 11, as appropriate::

3.1 The TEG proposes that the proceeds from EU green bonds be allocated to green projects (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report).

Do you agree that green projects may include the following items?

a) eligible green assets including physical assets and financial assets such as loans;

b) the share of the working capital that can reasonably be attributed to the operation of such eligible, tangible or intangible, green assets;

c) eligible green operating expenditures related to improving or maintaining the value of eligible assets;

3.2 Please add any comments to your replies to question 3.1, as appropriate:

4.1 The TEG proposes (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report) that eligible green expenditures qualify for refinancing with a maximum three years look-back period before the issuance year of the EU green bond, while eligible green asset qualify with no maximum look-back period.

Do you agree that a maximum look-back period be imposed with regard to the refinancing of eligible green expenditures?

a) Do you agree that a maximum look-back period be imposed with regard to the refinancing of eligible green expenditures?

b) Do you agree that a no maximum look-back period be imposed with regard to the refinancing of eligible green assets?

4.2 If any of your answers to question 4.1 is no, what is the maximum look-back period you would propose for reference in the EU Green Bond Standard? Please explain your view:

5.1 The TEG proposes (Section 3.3.1 of the report) that in cases where:

  1. the Taxonomy is not yet in force;
  2. the technical criteria are not yet available;
  3. or when technical criteria are considered not directly applicable due to the innovative nature, complexity, and/or the location of the green projects,

the issuer be allowed to rely on the fundamentals of the Taxonomy to verify the alignment of their green projects with the Taxonomy.

Do you agree with this approach?

5.2 Please add any comments to your reply to question 5.1, as appropriate:

6.1 The TEG proposes (Section 4.1 of Annex 1 draft model of the EU Green Bond Standard to the report)) that the issuer produces a green bond Framework (GBF) which confirms the voluntary alignment of green bonds with the EU Green Bond Standard and provides details on key aspects of the use of proceeds and the issuer’s green bond strategy and processes.

Do you agree with the envisaged content and role of the GBF?

6.2 Please add any comments to your reply to question 6.1, as appropriate:

7.1 The TEG proposes (Section 4.3 of Annex 1: draft model of the EU Green Bond Standard to the report) that the EU green bond issuer reports at least annually, until full allocation of the bond proceeds to green projects and thereafter, in case of any material change in allocation.

Please express your agreement with the proposed recommendations by using the scale from 1 to 5 (1 indicating no agreement):

a) Statement of compliance with the EU Green Bond Standard

b) Amount allocated to each green projects or green project categories; with the classification of such projects according to the EU Taxonomy and/or to EU environmental objectives

c) Nature of green projects (assets, capital expenditures, operating expenditures, etc.)

d) Share between green project financing and refinancing

e) Share of green projects financed by the issuer (if applicable)

f) Actual or estimated impact of the green projects based on metrics outlined in the GBF

g) Regional distribution of green projects

h) Green bond ratio

7.2 Please add any comments to your replies to question 7.1, as appropriate:

8.1 The TEG proposes (Section 4.4 of Annex 1: draft model of the EU green bond standard to the report) that the issuer appoints External Reviewers to verify both:

  1. before or at issuance, the issuer’s GBF, AND;
  2. after allocation of proceeds,

the EU green bond allocations and the actual or estimated impact reporting provided by the issuer.

Do you agree with this approach to verification as proposed by the TEG?

8.2 Please add any comments to your reply to question 8, as appropriate:

9. The TEG puts forward (Section 5 of the report) for consideration by the European Commission, a series of proposals for incentives to support the EU green bond market.

Do you have any comment on the incentives stated in the Section 5.1?

10.1 Some of these proposals stated in 5.2 pose challenges to their implementation – requiring the engagement of several authorities, the acquisition of new competencies and involving prolonged timelines. These proposals will require further analysis by the TEG as well as outreach and feedback from a broad range of stakeholders.

Please express your view on the potential effectiveness of such proposals using the scale from 1 to 5, with 1 indicating no effectiveness:

a) Tax incentives at issuer or investor level (including accelerated depreciation for assets financed by green bonds and loans)

b) Favoring EU green bonds in relevant financial sector regulation and prudential rules

10.2 Have you considered any other proposals for incentives in addition to the ones outlined by the TEG in Section 5 of the report?

Please comment as appropriate:

11.1 The objective of the EU GBS is to support the scaling up of the green bond market in the EU, while at the same time safeguarding the integrity of this market.

Through which of the means is the EU GBS likely / unlikely achieve to this objective?

Please express your view using the scale from 1 to 5, with 1 indicating unlikely.

a) Alignment of eligible green projects with the EU Taxonomy – expected to reduce uncertainty over greenness and provide clear guidance

b) Clarification with regards to some key elements involved in green bond issuance: tracking of proceeds, nature of eligible assets / expenditures – expected to reduce uncertainty and provide clear guidance

c) Requirement for the publication of issuer’s GBF and for allocation- and impact reporting – expected to increase transparency and promote standardisation in provision of information

d) Mandatory external review (and accreditation of reviewers – expected to support reliability of information, market integrity, and promote standardisation in provision of information

11.2 Please add any comments to your replies to question 11, as appropriate:

12. Are there any other relevant issues that you would like to bring to the attention of the TEG:

Please comment as appropriate:

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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