ICDQ ACCREDITED ENTITY FOR THE VALIDATION OF THE SELF-ASSESSMENT OF COMPLIANCE WITH THE DNSH PRINCIPLE. Enric Nebot, November 2022

Validation of the self-assessment of compliance with the DNSH principle

In response to the economic and social damage caused by the pandemic, the European Union has developed a recovery tool known as “Next Generation EU”. For its development, the European Union has defined several elements of recovery and financing, among which the European Recovery and Resilience Facility (RRF) stands out.

Spain, responding to the requirements established by the MRR, presented its Recovery, Transformation and Resilience Plan to the European Commission during the month of April 2021.

Total estimate for Spain (MRR + REACT-EU):

MRR: €69.528 billion of non-refundable transfer + a maximum of €80 billion in loans

REACT-EU Fund: €12 billion non-reimbursable transfer

During the coming months, and until the end of 2023, the State will issue new aid, and adapt the existing aid that will be granted to investment or reform projects that are part of one (or several) of the 30 components contemplated in the Recovery, Transformation and Resilience Plan.

The European Recovery and Resilience Facility (RRF) allows funding only for projects that respect the “do not cause significant harm” (DNSH) principle.

What is the DNSH principle?

The DNSH (Do No Significant Harm) Principle is a condition defined by the Commission that requires a self-assessment to ensure that the investment or reform does not adversely affect one, or several, of the 6 environmental objectives defined in Regulation 852/2020:

1. Climate Change Mitigation.
2. Adaptation to Climate Change.
3. Sustainable use and protection of water and marine resources.
4. Circular Economy, including waste prevention and recycling.
5. Prevention and control of pollution to air, water or soil.
6. Protection and restoration of biodiversity and ecosystems.

The organization must carry out this self-assessment considering the life cycle of the project.

Likewise, investment or reform projects whose actions opt for financing from these European funds, must have a self-assessment that explains that it complies with the principle of not causing significant damage to the environment (DNSH).

Validation of the DNSH Self-Assessment

The self-assessment of compliance with the DNSH principle carried out by the organization for each project may require a Validation Report of the same, carried out by a third party accredited as ICDQ, which supports the conclusions of the self-assessment and guarantees that these have a technical basis and are reasonable.

ICDQ, as one of the accredited entities, offers this process of validation of the self-assessment, after which it will issue a Validation Report on compliance with the DNSH principle of the project, which will be delivered to the organization.

This accredited Validation Report necessary for the different state calls or the Autonomous Communities can additionally contribute to the necessary confidence of any Interested Party.

What documentation is required for Validation?

• A descriptive report of the project and the investment, according to the structure and content of the call for aid to which it chooses.
• Self-assessment of compliance with the DNSH principle of the project and its actions, for each of the six environmental objectives
• Any other necessary document that establishes the call for aid to which you choose.
• Information/documentation to support the findings of the self-assessment and ensure that the self-assessment is technically based and reasonable

ICDQ will evaluate the information provided, carrying out a validation process that ends with the issuance of an Opinion on compliance with the DNSH principle (Validation Report of the project for which Next GEN funding has been requested)

Assurance of the allocation process and control and audit systems

In order to ensure the correct allocation and compliance with the requirements, the Administration has established as Control Authority the General Comptroller of the State Administration (IGAE) and has defined a series of control and audit systems:

• Internal control of the executing body.
• Control of an independent body.

ICDQ, as a member of the Business and Climate Foundation, is available to the Foundation and all its partners to collaborate in this matter.

Enric Nebot Teixidó

Commercial and Expansion Director of ICDQ

Company Member of the Private Company and Climate Foundation