The Commission’s ‘do no significant harm’ concept paper: Clearer approach welcome but major loopholes must be closed

Position paper    |    14 September 2026

This position paper examines the European Commission’s concept paper on the ‘do no significant harm’ (DNSH) principle under the next EU long-term budget.

The concept paper, which forms the basis for the Commission’s forthcoming DNSH guidance, brings a welcome unification of the DNSH criteria across EU funds, and provides mostly clear criteria for excluding activities that cause significant harm from EU funding.

However, this position paper finds major loopholes in the Commission’s plans for the DNSH principle and provides recommendations to make them fit for purpose.