Policy Documents

The European Geothermal Energy Council (EGEC) welcomes the European Commission’s initiative to review the Climate and Environmental Delegated Acts of the EU Taxonomy legislation. We strongly support the objectives of simplification, reduction of administrative burden, and alignment of Taxonomy with the EU’s industrial and climate ambitions. In this context, and with the intention of contributing to a more coherent and technology-neutral sustainable finance framework, we wish to suggest the following modifications. Remove the emission threshold and mandatory LCA requirements for geothermal technologies Create a coherent taxonomy category for geothermal heat pumps Clarify the scope of the “Manufacturing of renewable energy technologies” category Address practical challenges in DNSH criteria for DHC networks   EGEC Response to the Call for Feedback on EU Taxonomy – Review of Climate and Environmental Delegated Acts (PDF)  

EGEC 's proposals for a European Geothermal Strategy and Action Plan, published on 5 December 2025. 

Planned for publication in the second quarter of 2026, the EU Heating and Cooling Strategy will support the implementation of current legislation to accelerate decarbonisation of the sector and improve its efficiency and system integration through integrated planning of energy infrastructure district heating and cooling development waste heat recovery It will address both supply and demand by accelerating the deployment of clean heating and cooling, and by encouraging their use in important sectors such as buildings and industry. EGEC submitted its response to the stakeholder consultation on 19 November 2025.   EGEC's response to consultation on the Heating and Cooling Strategy (PDF)

On 3 October 2025, the European Investment Bank published the Climate Bank Roadmap for the 2026-2030 period together with an Energy Sector Orientation. EGEC contributed by responding to the consultation of civil society organisations and other stakeholders, which closed on 7 August 2025.   EGEC's response to consultation on the EIB's Climate Bank Roadmap and Energy Sector Orientation (PDF)

In the preparations for the first ever European Affordable Housing Plan, the Commission carried out the Affordable Housing Dialogue throughout 2025. The scope was to collect knowledge and data from stakeholders across Member States. EGEC contributed to the call for evidence that closed on 4 June 2025.   EGEC's response to consultation on the European Affordable Housing Plan (PDF)

The Modernisation Fund supports the modernisation of energy systems and the improvement of energy efficiency in 13 lower-income EU Member States. Established in 2018 for the 2021-2030 period, it aims to help the beneficiary Member States achieve their climate targets and the objectives of the European Green Deal. The beneficiary Member States are Bulgaria, Czechia, Estonia, Greece, Croatia, Latvia, Lithuania, Hungary, Poland, Portugal, Romania, Slovenia and Slovakia. In 2025, the European Commission launched an initiative to evaluate the Modernisation Fund’s operating rules. EGEC submitted its contribution to the Call for Evidence on 26 May 2025.   EGEC response to the consultation on the Modernisation Fund (first evaluation of the operating rules) (PDF)

In February 2025, the European Commission announced in the 'Communication on the Clean Industrial Deal: A joint roadmap for competitiveness and decarbonization' a new auction to promote the decarbonization of key industrial processes, drawing on the experience of the hydrogen auctions of the Innovation Fund. It was proposed to allocate the budget of up to EUR 1 billion through fixed-premium auctions in support of projects that decarbonise industrial process heat through innovative electrification technologies such as heat pumps, electric boilers, resistance heating, induction heating, plasma heating and other solutions as well as renewable heat solutions (solar thermal and geothermal). First ideas for the auction scope and design were presented and discussed with stakeholders during a Workshop on 16 April 2025. As a follow-up, the European Commission invited all interested stakeholders to provide feedback on the proposed design elements of the new auction by participating in a survey. EGEC took part in the survey on 15 May 2025.   EGEC's response to consultation on Innovation Fund Heat Auction (PDF)

On 25 June 2025, the European Commission adopted a new State aid framework accompanying the Clean Industrial Deal (CISAF), which is designed to help Member States support the development of clean energy, industrial decarbonisation and clean technology. EGEC contributed to the public consultation which closed on 25 April 2025.   EGEC's response to consultation on the Clean Industrial Deal State Aid Framework (CISAF) (PDF)

In January 2025, the European Commission opened a call for feedback on Renewable energy auctions – Implementing Act on non-price criteria in the framework of the Net-Zero Industry Act. EGEC submitted its contribution on 17 February 2025.   EGEC contribution to the Call for feedback on Renewable energy auctions – Implementing Act on non-price criteria (PDF)

On 8 January 2025, the Platform on Sustainable Finance published a draft independent report on preliminary recommendations for the review of the Climate Delegated Act and the addition of activities to the EU taxonomy for sustainable activities. EGEC responded to the call for feedback, which closed on 5 February 2025. EGEC also wrote to Valdis Dombrovskis, EU Commissioner for Economy and Productivity. EGEC called for simplification of the Sustainable Finance Taxonomy by placing geothermal on an equal footing with wind and solar energy in relation to lifecycle emissions, as the existing rules put a brake on capital market investments in geothermal.  Geothermal energy technologies are clearly identified as sustainable investments in the sustainable finance taxonomy. Geothermal power plants, geothermal district heating and cooling, geothermal cogeneration, geothermal heat pumps, UTES and other forms of thermal energy storage can all be eligible as a “sustainable investment”. Nevertheless, pursuant to the substantial contribution criterion to climate change mitigation, the production of geothermal electricity and heat and cool generation are all required to comply with an emission threshold of LCE<100g CO2e/kWh verified by independent third party. This criterion is not asked for other renewable energy sources.  EGEC contribution in brief  EGEC deems that the abovementioned threshold should be removed for all geothermal technologies for the following reasons:  As regards the respect to the ability to comply with and/or implement (e.g. technical feasibility) the technical screening criteria for substantial contribution of the activity, the criteria put in place for geothermal appear to be unfair when compared to the ones applied to other renewables. The EU taxonomy has so far sent the wrong signal for electricity, heat and cool generation from geothermal energy, despite the low CO2 eq/kWh.  After evaluating several scientifically based life cycle analyses for geothermal plants, it can be stated that the threshold value of 100gCO2-eq/kWh specified in the EU taxonomy for the LCA is always undercut for representative plants. This threshold should then be removed for all geothermal technologies.  The obligation to carry out an LCA is seen as an additional obstacle for geothermal heat and cool generation.  The mandatory performance of an LCA contradicts the general endeavour to speed up the planning and construction of geothermal plants.  Therefore, EGEC wishes to see the same criteria applied to all renewable energy technologies and proposes then to erase from Commission delegated Regulation (EU) 2021/2139 the threshold for geothermal and the LCA obligation required to geothermal activities to comply with the substantial contribution to climate change mitigation.    EGEC's response to consultation on the EU Taxonomy Regulation (PDF)