DNSH principle in Horizon Europe

What is the “Do No Significant Harm (DNSH) principle”?

DNSH stands for "do no significant harm". To understand what this term fully covers, we need first to introduce sustainable activities. The EU Sustainable Taxonomy has been introduced as a classification system allowing to determine what can be considered as a sustainable activity according to several horizontal criteria.

A sustainable activity is expected to be significantly contributing to the environmental objectives AND it should also not harm any of those 6 objectives:

• Climate change mitigation
• Climate change adaptation
• Sustainable use & protection of water & marine resources
• Pollution prevention & control
• Transition to a circular economy
• Protection and restoration of biodiversity & ecosystems

These 6 objectives can be explained as follows. An activity is considered to DO significant HARM to:

• climate change mitigation if it leads to significant greenhouse gas (GHG) emissions;
• climate change adaptation if it leads to an increased adverse impact of the current climate and the expected future climate, on the activity itself or on people, nature or assets This means specifically that significant harm to the objective of climate change adaptation can be done by either (i) not adapting an activity to the adverse impacts of climate change when that activity is at risk of such impacts (such as a building in a flood-prone area), or (ii) by maladaptation, when putting in place an adaptation solution that protects one area (“people, nature or assets”), while increasing risks in another area (such as building a dyke around a plot in a flood plain which results in shifting the damages to a neighbouring plot that is not protected);
• the sustainable use and protection of water and marine resources if it is detrimental to the good status or the good ecological potential of bodies of water, including surface water and groundwater, or to the good environmental status of marine waters;
• the circular economy, including waste prevention and recycling, if it leads to significant inefficiencies in the use of materials or in the direct or indirect use of natural resources, or if it significantly increases the generation, incineration or disposal of waste, or if the long-term disposal of waste may cause significant and long-term environmental harm;
• pollution prevention and control if it leads to a significant increase in emissions of pollutants into air, water or land;
• the protection and restoration of biodiversity and ecosystems if it is significantly detrimental to the good condition and resilience of ecosystems, or detrimental to the conservation status of habitats and species, including those of Union interest;

What does the DNSH principle mean in the context of Horizon Europe?

At programming stage, the Horizon Europe Work Programme has been co-created to support research and innovation activities that respect climate and environmental priorities of the Union and cause no significant harm to them.

References on the DNSH principle were included in the General Introduction of the applicable Horizon Europe Work Programme (2021-2022 and 2023-2024) because of their particular relevance for environmental outcomes and impacts.

Areas where DNSH is relevant

Pillar I – Excellent Science

The principle is not applicable.

Pillar II – Global Challenges

Since the update of the Horizon Europe Programme Guide and proposal templates applicable from Work Programme 2025 onwards, the general requirement for applicants to explain compliance with the Do No Significant Harm (DNSH) principle has been removed from Horizon Europe proposals. As a result, evaluators will no longer score applications in relation to their compliance with the DNSH principle unless explicitly stated in the work programme.

However, some topics may still contain specific DNSH requirements. In such cases, applicants should explain how the proposed activities comply with the DNSH principle and demonstrate that the project will not carry out activities that cause significant harm to any of the six environmental objectives defined in the EU Taxonomy Regulation.

Possible environmental consequences should still be considered under excellence and impact criteria as appropriate.

In particular, the potential harm of Innovation Actions contributing to the European Green Deal . Horizon Europe projects will play an important role to help economic operators reach or go beyond the standards and thresholds set up in the Regulation as technical screening criteria and to keep them up-to-date. Alignment of research and innovation activities with EU Taxonomy technical screening criteria will also be piloted in selected topics with the aim to facilitate their later access to green finance to foster the market uptake of the innovative technologies and solutions they developed.

Further reading

• programme-guide_horizon_en.pdf (europa.eu) p39
• EU taxonomy regulation
• Technical Guidance on DNSH evaluations for specific cases:
• Commission Delegated Regulation (EU)
• Information from European Union Institutions, Bodies, Offices and Agencies