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Executive summary:
ASECAP welcomes the European Commission’s initiative to revise the EU Taxonomy framework, viewing it as a key opportunity to address practical challenges identified since its implementation. These include the complexity of technical screening criteria, inconsistencies between legal provisions and guidance, and resulting difficulties in usability, legal certainty, and market uptake. ASECAP supports efforts to improve clarity, proportionality, and operational applicability. Road infrastructure and tolling activities should be recognized as relevant to the transition to sustainable mobility.
Beyond financing, tolling contributes to climate mitigation, adaptation, pollution reduction, and more efficient infrastructure use, as reflected in the Eurovignette Directive. Digital solutions, including intelligent transport systems (ITS), also play an increasing role in enabling efficient and low-carbon mobility. A key issue concerns Activity 6.15 of the Taxonomy.
While the legal text focuses on specific physical infrastructure (e.g. charging stations), Commission guidance acknowledges that digital solutions such as ITS, traffic optimization, and electronic tolling may also qualify when they reduce emissions and improve efficiency.
However, this broader interpretation is not reflected in the current draft revision, creating a structural inconsistency between legal provisions, guidance, and revised criteria. This misalignment generates legal uncertainty, divergent market interpretations, and barriers for operators, auditors, and investors. It also risks excluding digital solutions that deliver significant environmental benefits, thereby reducing the effectiveness and credibility of the framework.
More broadly, ASECAP stresses that decarbonization of road transport is increasingly driven by a combination of physical infrastructure and system-level optimization. While the Taxonomy recognizes the former, it insufficiently reflects the role of digital and operational solutions. This may lead to an incomplete representation of how emissions reductions are achieved in practice.
ASECAP also highlights wider implementation challenges, including lack of clarity on compliance, inconsistencies between rules and guidance, and overly granular technical criteria, particularly under Do No Significant Harm requirements. These can create disproportionate administrative burdens and hinder investment. Similar issues arise in other road-related activities and in climate adaptation provisions.
Uncertainties also affect the application of Activity 6.15 under the climate adaptation objective, especially following the restructuring of criteria in the draft Delegated Act. Clarification is needed on how motorway operators activities such as ensuring infrastructure resilience should be assessed.
ASECAP recommends explicitly recognizing digital and system-level solutions (e.g. ITS, traffic management optimization, electronic tolling) as contributing to climate mitigation under Activity 6.15, with clear technical criteria. If legal revision is not feasible, authoritative clarification should ensure alignment between the Regulation, guidance, and criteria.
Further guidance is also needed on applying generic criteria in practice. More generally, the Taxonomy should better reflect both physical and digital dimensions of infrastructure, as well as complementary investments such as renewable energy installations and energy-efficient road lighting. Greater clarity is also needed on concession-based models and their treatment in Taxonomy KPIs. In conclusion, addressing the inconsistency in Activity 6.15 would improve legal certainty, consistency, and practical applicability, while ensuring the Taxonomy reflects real-world pathways to low-carbon mobility. Aligning the framework with technological progress and system-level solutions is essential for effectively guiding sustainable investment.
