EUSTAFOR responds to the EU consultation on DNSH Guidance for the 2028–2034 MFF

The European Commission is developing technical guidance on how the “Do No Significant Harm” (DNSH) principle will apply across all EU-funded programmes under the next long-term budget (2028–2034). This consultation is a key step in shaping how environmental safeguards will be operationalised and who bears the burden of proving compliance.

EUSTAFOR submitted its contribution on 1 April 2026, making the case that the DNSH guidance must work with existing national systems, not against them. Our central ask: Forest Management Plans (FMPs), which are validated by national authorities and grounded in scientific data, should be recognised as de facto proof of DNSH compliance. Adding a new layer of EU-level requirements on top of these plans would create unnecessary administrative burden without delivering additional environmental value, particularly given that preparing an FMP already costs up to €90/ha. We also stressed the importance of subsidiarity, urging the Commission to avoid prescribing detailed silvicultural requirements that are inherently local and ecological in nature, and flagged data security risks associated with increased reporting obligations.

How the Commission translates this guidance into practice will have direct consequences for whether EU funds can flow efficiently into sustainable forestry or get stuck behind red tape. EUSTAFOR will continue to monitor and engage as the guidance takes shape.