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Do No Significant Harm, broader implementation in EU R&I programmes remains premature

The European University Association (EUA) fully supports the environmental objectives outlined in the EU’s sustainable finance taxonomy regulation. However, broadening the application of the Do No Significant Harm principle to all projects under European R&I framework programmes (i.e. Horizon Europe and any eventual successor programme), as foreseen in the European Commission’s proposal for the recast of the EU Financial Regulation, is still premature.

Therefore, EUA does not support the unconditional introduction of this principle in the regulation. Together with CESAER and Science Europe, the Association calls for the European Parliament to support amendment 165*, which inserts important considerations concerning feasibility, appropriateness and proportionality.

There are several reasons for this:

• The introduction of the Do No Significant Harm principle creates an additional administrative burden and adds to the complexity of project proposals and evaluations. EUA has advocated for programme simplification for many years. The broader application of the principle must not come at the cost of additional burden for researchers.
• There are no clear guidelines on how the principle should be implemented in practical terms.
• If the principle becomes an obligation for all framework programme projects, including in Horizon Europe’s Pillar I and for projects with lower technology readiness levels (TRLs) in Pillar II, researchers may struggle to undertake certain types of (fundamental) research.
• The broader application of the principle must be preceded by a thorough assessment of its implementation in the Horizon Europe, as the ongoing programme.

Do No Significant Harm and Horizon Europe, the context to date

The Do No Significant Harm principle is a novelty in Horizon Europe. Introduced in the regulation to establish a sustainable finance taxonomy at EU level, the principle states that research and innovation activities should not support or carry out activities that create significant harm to any of the objectives of the European Green Deal. In other words, it is intended to force beneficiaries to think about the possible negative climate and environment impacts of their projects.

The principle is currently applicable to selected components of Horizon Europe, notably in European Innovation Council projects, and missions and clusters of Pillar II that are of particular relevance for environmental outcomes and impacts. Notably, the principle is currently not applicable to fundamental research projects supported by Pillar I.

The Commission is now proposing to introduce the principle to the EU Financial Regulation, which is the basis for all European funding programmes. This means that it would be automatically applicable to all framework programme projects, including in Pillar I.

*(d) programmes and activities shall, where feasible, appropriate and proportionate, in accordance with the relevant sector-specific rule, be implemented to achieve their set objectives without doing significant harm to the environmental objectives of climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention and control and the protection and restoration of biodiversity and ecosystems, as set out in Article 9 of Regulation (EU) 2020/852 of the European Parliament and of the Council.