Spain asks the European Commission to add 'Resilience' to the DNSH principles

The Government of Spain has formally requested the European Commission to expand and strengthen the DNSH principle to transform it into a combined approach called "DNSH + Resilience" (DNSH+R).
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The DNSH principle (Do No Significant Harm or "Not to cause significant harm to the environment") in Spain is a mandatory criterion set by the European Commission. Its main objective is to ensure that none of the investments or reforms financed with European funds —especially those from the Recovery, Transformation and Resilience Plan (PRTR)— harm the ecological objectives of the region. 

The European Commission is holding a public consultation on the draft of the future DNSH guidelines in anticipation of the upcoming Multiannual Financial Framework (2028-2034). This aims to standardise the evaluation criteria, provide greater legal certainty to Spanish companies, and reduce differences in administrative interpretation among the various European programmes. 

The Government of Spain has formally requested the European Commission to expand and strengthen the DNSH principle to transform it into a combined approach called "DNSH + Resilience" (DNSH+R).

The aim of this proposal is for investments financed with European funds to not only demonstrate that they "do not cause significant harm" to the environment, but also to mandatorily assess long-term climate risks and enhance the adaptation and resilience capacity of infrastructures against extreme phenomena (such as droughts or large fires).

The request was formalised in early September 2026. It has been strategically timed with this moment because the European Commission is preparing its new Climate Resilience Strategy, which is expected to be presented at the end of this year, in addition to the guidelines for the upcoming Multiannual Financial Framework (the EU budget).

Aware that many companies and administrations already consider the current DNSH process a heavy administrative burden, Spain has specified in its proposal that this evolution towards the resilience approach must be done "in a smart and proportionate manner." The Ministry's idea is to leverage existing tools, audits, and reporting methodologies, avoiding duplicating procedures or adding unnecessary bureaucracy for fund applicants.

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