Ensuring the Significance of "Do No Significant Harm"

Shortfalls of the DNSH principle and recommendations for improvement

The implementation of the do no significant harm (DNSH) principle is a major step forward in efforts to subject investments, particularly public investments, to closer scrutiny of their contributions to the green transition. The DNSH is important because it requires a more holistic consideration of the impacts that reforms and investments will have on other policy areas. This presents an excellent and essential opportunity to prevent harmful trade-offs and improve environmental outcomes.

However, while the DNSH is an important step towards meeting multiple objectives at a time, our analysis of Member States’ National Recovery and Resilience Plans (NRRPs) under the Recovery and Resilience Facility (RRF), has shown that the application of this principle did not reach its full potential. There have been significant gaps and inconsistencies in application.

A more robust and coherent application and implementation of this principle is critical, especially as this method will now also be used for future funding instruments at EU level. This policy brief investigates the application of the DNSH assessment in the Member States’ (MS) National Recovery and Resilience Plans (NRRPs) as a basis for guidance for a more rigorous and evidence-based application in the future.

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