Definition and application of the DNSH principle
The Do No Significant Harm principle (DNSH) states that the actions outlined in national NRRPs may not cause any significant harm to the environment: this is a fundamental principle for accessing funding from the RRF. In addition, the plans must include actions which contribute 37% of the resources to the ecological transition.
The DNSH principle is based on the provisions of the "Taxonomy for Sustainable Finance" adopted to promote private sector investment in green and sustainable projects and help achieve the goals of the Green Deal.
Criteria of DNSH
The Regulation identifies six criteria for determining how each economic activity substantially contributes to protecting the ecosystem, without undermining any of the environmental goals:
An economic activity must not lead to significant emissions of greenhouse gases (GHG).
An economic activity must not have an increased negative impact on the current and future climate, on the activity itself or on people, nature or property.
An economic activity must not be detrimental to the good health of water bodies (surface, groundwater or marine) or harm its quality or reduce its ecological potential.
An economic activity must not result in significant inefficiencies in the use of recovered or recycled materials, increase the direct or indirect use of natural resources, or significantly increase waste or the burning or disposal thereof, causing significant long-term environmental damage.
An economic activity must not cause increased emissions of pollutants in the air, water or soil.
An economic activity must not harm the good condition and resilience of ecosystems or the conservation status of habitats and species, including those of interest to the Union.
A specific technical annex of the Taxonomy sets out the parameters for evaluating whether different economic activities substantially help with climate change mitigation and adaptation or whether they cause significant harm to one of the other goals. Based on the Statistical Classification of Economic Activities in the European Community (NACE), the activities that can help to mitigate climate change are then determined, identifying the sectors that are crucial for an effective reduction in pollution. The framework defined in the Taxonomy therefore provides a reliable guide for making sustainable investment decisions, and has become a core component of the criteria for allocating European resources.
DNSH assessments for the NRRP
All the measures inserted in the NRRPs must comply with the DNSH principle and it is the responsibility of Member States to demonstrate this compliance.
All the projects and reforms proposed in the Italian National Recovery and Resilience Plan have therefore been assessed in consideration of DNSH criteria. As per the European guidelines, the technical assessment has estimated the direct and indirect effects for each action from a long-term perspective.
The effects of each investment or reform on the six environmental objectives have then been assigned to four distinct scenarios:
The measure has zero or negligible impact on the goal
The measure supports the goal with a coefficient of 100%*
The measure "substantially" contributes to the environmental goal
The measure requires a comprehensive DNSH assessment
Having identified these scenarios, two approaches have been defined for DNSH assessments:
1) Simplified approach
Adopted if, for an individual goal, the action can be classified in one of the first three scenarios. The administrations then provided a brief justification to highlight the reasons that the action is associated with a limited risk of environmental damage, regardless of its potential contribution to the green transition.
2) Detailed analysis and conditions that must be respected
To be adopted for investments and reforms that fall within sectors such as energy, transport or waste management, and which present a greater risk of affecting one or more of the environmental goals. The same analysis was also required for actions that aim to make a substantial contribution to climate change mitigation.
DNSH sheets for NRRP reforms and investments
The DNSH sheets can be filtered by mission and component: the first page of each file shows the table of contents with the list of reforms and investments contained in the file, and the subsequent pages contain the assessment sheets for the individual actions.
Digitalisation, innovation, competitiveness, culture and tourism
Green revolution and ecological transition
Infrastructure for sustainable mobility
Education and research
Inclusion and cohesion
Operational guide for compliance with DNSH
The technical criteria reported in the DNSH self-assessments of the NRRP are guiding elements along the entire path of implementation of investments and reforms. The administrations are expected to concretely ensure that each measure does no significant harm to environmental objectives by adopting specific requirements in the main planning and implementation acts. In particular, the undertakings must result in precise warnings and must be monitored from the planning of the measure to the test or the release of the certificate of regular execution of the interventions. The financing decrees and the specific technical tender documents should clarify the essential elements that are necessary to fulfil the DNSH. Moreover, the documents should provide automatic administrative mechanisms that involve the suspension of payments and the advocation of the procedure in case of non-compliance with the DNSH.
Similarly, once the tenders have been activated, the design address document (“documento di indirizzo alla progettazione”) should provide technical information for the design application of the requirements for the DNSH compliance. The design and technical specifications as well as disciplinary documents should contain specific indications for the DNSH compliance in order to report a detailed description on the fulfilment of the DNSH in the work progress status (“SAL – stato avanzamento lavori”).
The DNSH Operational Guide aims to assist administrations in the process of orientation, gathering information and checking. It provides a guide in orientating among the taxonomic requirements and the legislation. The guide consists of:
By clicking on the crosses through the mapping table it is available a direct access to the technical data sheets of interest.
The DNSH Operational Guide provides guidance on taxonomic requirements, on the relevant legislation and it gives useful elements to document the DNSH compliance.
Reference documents and legislation
The Regulation identifies the criteria for determining how each economic activity contributes substantially to the protection of the ecosystem, without causing damage to any of the established environmental objectives