8. Recommen­dations

The recommendations aim to support a broader understanding of the Taxonomy, for more effective implementation across the Nordics over the upcoming years. As the EU taxonomy is still in its early stages, current practices are primarily focused on development and learning by doing. Each of the interviews presented a unique case and understanding of how the EU Taxonomy reporting is being adapted and adopted into company structures. Hence, the recommendations given in this section on the basis of the findings are of a more general character, to highlight the need for further understanding and interpretation of the effects on sustainability reporting. It has not been possible to provide country or sector specific recommendations since everyone is still in a learning phase where interpretations, reporting standards, and best practice is being formed along the way.

The following five recommendations are presented below and directed towards policy makers in the Nordics, companies obliged to report on the Taxonomy as well as financial stakeholders.  

National regulations are to some extent used by the companies as a baseline for fulfilling certain requirements of the EU taxonomy. However, further clarification is needed regarding whether, and if so, which regulatory compliance can be directly incorporated into taxonomy reporting and where actions beyond national legislation is required to align with the technical screening criteria outlined in the Taxonomy.

All the interviewed companies have chosen environmental objective one (climate change mitigation) as their primary focus for significant contribution. To align with environmental objectives 3-6 in the long term as outlined inthe Environmental Delegated Acts, there is a recognized need for increased demand, investments and development within the sectors to move beyond business as usual which is currently focused primarily on reducing climate impact.

The companies included in this study have all chosen environmental objective one, climate change mitigation, as as their primary focus for significant contribution. A further investigation into the distribution of substantial contributions across all six environmental objectives is needed to ensure that further sustainability measures extend beyond standard practices.

Since the Taxonomy Regulation still is in its infancy and is being implemented step by step across sectors and company-sizes, very little is known about the impact on sustainability practice. Therefore, as the Taxonomy becomes more established and standard practice for both companies and investors, research on impact to understand what effects the Taxonomy has on the market and different sectors will be vital in order to strengthen perception of the relevance and importance.

Many companies already use certification schemes to certify the sustainability work, and several of the most used certification schemes in the Nordics have begun the process of harmonising their criteria according to the Taxonomy. It is therefore important to further study the influence certification schemes might have on the interpretation and fulfilment of Taxonomy reporting, to which extent there are synergies between the requirements, and whether there is a need for third party audits of the claimed contributions. 

On a final note, there are difficulties in interpreting the EU taxonomy, which has been a reoccurring theme for the companies. Several suggestions to solve this has been raised by the companies, e.g. specific guidance on both national and Nordic level. Further guidance is not included in the recommendations, since the regulative framework for the Taxonomy is still under design and being developed while this report is published. And since the Taxonomy Regulation is being implemented across all EU member states, there are uncertainties regarding whether a national or Nordic guidance would complicate interpretations and adaptations further. With that said, there is a need for clarifications on interpretations and reporting practice to minimise uncertainties and deviations across nations, but whether that responsibility lies within the EU solely or at member state level remains to be seen.