DNSH without surprises: the two-part assessment for CDTI, PRTR and IDAE

The unit of analysis is the action

DNSH assesses each funded action, not the company in the abstract. It must show no significant harm to any of the six environmental objectives under Regulation (EU) 2020/852.

The two-part assessment

Technical guidance 2023/C 111/01 uses a clear sequence. Part 1 screens which objectives require substantive assessment. Part 2 records the reasoning, thresholds and evidence for each relevant objective. CDTI, PRTR and IDAE also require the result in the programme template.

Evidence by objective

• Mitigation: emissions inventory, consumption, factors and reduction plan.
• Adaptation: location-based physical risks and resilience measures.
• Water: consumption, discharges, permits and impacts.
• Circular economy: waste, useful life, reuse and recyclability.
• Pollution: substances, emissions and controls.
• Biodiversity: location, sensitive areas and preventive measures.

Frequent mistakes

Generic declarations, assessing the company instead of the action, unsupported claims, forgotten delivery commitments and broken links between application and final report all weaken the file. Using an outdated guidance version is another common failure.

Voombu structures one versioned file per action and lets an independent third party validate it inside the Portal. Voombu does not decide eligibility or issue an opinion.