EU Commission FAQs on EU Green Bond Regulation

On 6 November 2025, the European Commission published a Commission Notice on the interpretation and implementation of certain legal provisions of the European Green Bond Regulation (the “Regulation”), aiming to clarify certain existing requirements of the Regulation. 

The FAQs have been published in response to questions that have been raised by market participants and include clarification around:

• Use of the designation ‘European Green Bond’: how an issuer may re-label an existing EU Taxonomy-aligned bond as a ‘European Green Bond’ or ‘EuGB’ , as well the consequences of breach of the Regulation post-issuance, which may include the loss of the right to use the designation EuGB.

• Use of Proceeds/Allocations: permitted allocations under the gradual (or bond-by-bond) and portfolio approaches, including guidance on post-issuance reporting obligations under the portfolio approach, clarifying requirements around total value of assets in the portfolio exceeding the total value of EuGBs and confirming that a post-issuance review is not needed where the portfolio composition has not changed during the reporting period even if the overall value of such portfolio has diminished due to repayments.

• Use of Proceeds/EU taxonomy-alignment: eligibility of CapEx under the gradual approach, application of grandfathering under the portfolio approach, activities covered by the 15 per cent ‘flexibility pocket’, including how issuers and external reviewers can assess such activities against the requirements of the Regulation, and guidance specific to sovereign issuers, including around transition plans and evidencing EU Taxonomy-alignment for public expenditures. 

• EuGB factsheets and other disclosures: requirements for complying with the EuGB factsheet template (including using a factsheet for potentially multiple future issuances and obligations to update the information included therein), the interaction between a broader green bond framework and a factsheet and the validity of external reviews.

The Notice makes clear that the document and the 24 FAQs contained therein do not introduce any additional requirements but are merely intended to assist in interpreting and implementing certain legal provisions, noting that it is only the Court of Justice of the European Union that is competent to authoritatively interpret EU law.