EIC Board urges integrated ESG framework for deep tech and an EIC Fund reporting standard

Brussels, December 9th 2024
Summary
  • The EIC Board published recommendations calling for an integrated environmental, social and governance policy tailored to deep tech.
  • It asks the EIC and the Commission, as observer and sole investor in the EIC Fund, to develop an ESG reporting framework for the Fund and its portfolio.
  • The Board wants Business Acceleration Services to give hands-on support so early stage companies can meet ESG reporting expectations.
  • Recommended timeline calls for an initial framework in 2025 and fuller roll out and alignment across the ecosystem between 2025 and 2027.
  • The Board frames ESG as a catalyst for drawing like minded capital and improving resilience while noting the need to simplify reporting for startups.

EIC Board publishes ESG recommendations to shape responsible deep tech investing

On 9 December 2024 the European Innovation Council Board published a set of recommendations to integrate environmental, social and governance principles across the EIC and its investment ecosystem. The Board frames the move as a strategic effort to position the EIC and the EIC Fund as catalysts for responsible deep tech innovation across Europe. The document outlines concrete expectations for policy, reporting and services aimed at early stage and scaleup companies in the EIC portfolio.

What the Board recommends

The core recommendations are straightforward and ecosystem oriented. The EIC Board urges the EIC to take a leadership role in promoting responsible deep tech innovation. It asks the Commission and the EIC Fund to co‑design an ESG policy and a reporting framework for the Fund. It recommends that EIC Business Acceleration Services provide practical support to portfolio companies to implement ESG metrics and reporting. Finally, the Board calls for coordination across co‑investors to reduce duplicated reporting burdens.

RecommendationLead actorPurposeTarget timing
EIC to lead on responsible deep tech innovationEIC Board / EISMEASignal leadership and set expectations across the sectorInitial framework 2025
Develop ESG policy and reporting framework for the EIC FundCommission (observer) and EIC FundEnable engagement with investees and portfolio monitoringInitial framework 2025, implement 2025-2027
Embed practical ESG support in Business Acceleration ServicesEIC Business Acceleration ServicesHelp startups meet investor and regulatory reporting needsRoll out 2025-2027
Use Trusted Investors Network and partners to align reportingEIC, Trusted Investors Network and co-investorsReduce reporting burden and promote sectoral standardsOngoing from 2025

Why the Board says this matters

The Board presents ESG adoption as both a reputational and a financial lever. It argues that a clear ESG policy will help attract capital from investors who prioritise sustainability and responsibility. The recommendations also position ESG practices as a way to make portfolio companies more resilient and future proof as they scale. The Board underlines that many SMEs already face indirect reporting expectations from corporate partners and that preparedness will become a direct issue as regulatory thresholds and investor demands evolve.

Trusted Investors Network (TIN):A forum recently launched to coordinate practices between the EIC Fund and private co-investors. The Board suggests using TIN to promote coherence in ESG practices and to minimise duplicated requests for portfolio companies.
Business Acceleration Services (BAS):A set of support services the EIC already offers such as coaching, mentoring and market access help. The Board recommends BAS include hands-on ESG support to help startups implement metrics and reporting aligned with market practice.

Context from the EU innovation ecosystem

The EIC is one of Europe’s largest public deep tech investors. Its portfolio sits at the intersection of frontier R and D and commercialisation. At the same time, the EU regulatory landscape for sustainability disclosure is maturing. The Corporate Sustainability Reporting Directive and the EU taxonomy are changing what companies must disclose and how investors assess companies. While many of these rules currently target larger companies and funds, knock‑on effects reach startups through supply chain requirements, investor due diligence and fund-level reporting obligations.

Corporate Sustainability Reporting Directive (CSRD):EU legislation that progressively expands mandatory sustainability reporting obligations. Initially focused on large and listed companies, the CSRD generates downstream expectations for suppliers and portfolio companies as investors and corporates seek consistent data.
EU Taxonomy and SFDR:The EU Taxonomy provides a classification for environmentally sustainable activities. The Sustainable Finance Disclosure Regulation sets transparency obligations for financial market participants. Together they shape how funds position sustainability claims and how investors screen opportunities.

How the Board wants implementation to proceed

The Board proposes a two phase approach. First, put in place an overarching ESG framework in 2025 that sets objectives, policy strands and a timetable. Second, from 2025 to 2027 complete roll out including practical BAS support and coordinated discussions with co‑investors to align reporting expectations. The Board is explicit that the EIC already has some building blocks in place such as selection and evaluation criteria, ethics reviews and some BAS offerings, and that the policy should build on those foundations.

PhaseActionsExpected outputsTiming
Phase 1Design overall ESG framework and EIC Fund reporting standardPolicy document, reporting template, governance for implementation2025
Phase 2Deploy BAS ESG services and coordinate with co-investors via TINCoaching modules, harmonised reporting expectations, portfolio monitoring2025 to 2027

Practical challenges and risks the Board glosses over

The Board stresses benefits but does not fully detail the operational trade‑offs. Startups and early stage companies often lack data collection systems, dedicated sustainability staff and bandwidth to respond to complex reporting requests. Introducing ESG requirements without proportionality risks adding administrative burden and creating distraction from core R and D work. There is also the well documented risk of greenwashing if standards are vague. Finally, sharing data with multiple stakeholders raises legitimate concerns about confidentiality and intellectual property for frontier technology developers.

Proportionality and materiality:Practical ESG frameworks for startups must apply proportionality so reporting requests match company size, risk profile and material issues. Materiality assessments identify which ESG factors are most relevant to a company and should guide reporting.

Implementation will require resource choices. The EIC and the Commission will need to decide whether BAS support is delivered centrally or through partners, and whether templates or IT tools are provided to automate data capture. The Board names the Trusted Investors Network as a vehicle for alignment. That is promising but voluntary network effects may be insufficient unless the EIC Fund or the Commission set clear minimum requirements.

Standards, metrics and technologies the EIC should weigh

If the EIC wants its ESG framework to be credible it will have to choose which reporting standards and metrics to use or map to. Options include established reporting frameworks and technical standards used by investors and corporates. These choices affect comparability, implementation costs and the risk of diverging expectations across co‑investors.

Common reporting frameworks to consider:Frameworks such as GRI, SASB, IFRS S1 and S2 and the EU sustainability taxonomy are commonly used. Impact frameworks such as IRIS Plus are used for social and impact metrics. The EIC will need to decide how to map or reconcile these with the practical realities of deep tech startups.

What to watch next

The Board's recommendations are a policy signal rather than an immediate rule change. Key next steps to monitor are whether the Commission and the EIC Fund translate the recommendations into a published ESG policy and reporting framework, how prescriptive that framework will be, and whether BAS services receive additional funding and staffing to deliver hands-on support. Observers should also watch whether the EIC Fund conditions or investment processes start to include ESG dialogue or monitoring as standard practice.

A broader question is coordination with EU disclosure rules and market participants. If the EIC leads in promoting harmonised, proportionate reporting that reduces duplicate demands on startups, it will create practical benefits. If instead the EIC adds another set of non‑aligned expectations it could increase complexity for portfolio companies. The Board has signalled the direction. Execution will determine whether the policy improves the investment environment or adds administrative friction for the deep tech firms it aims to help.

For policymakers and ecosystem actors

Policymakers should support proportionality, tooling and funding for capacity building when introducing new reporting expectations for small and young companies. Investors and co‑investors should engage in the harmonisation effort while protecting commercially sensitive information. Startups should engage proactively but push for clear, minimal datasets that meet investor and regulatory needs without unduly diverting technical teams.

In short, the EIC Board recommendation establishes a coherent ambition to mainstream ESG across Europe’s deep tech financing ecosystem. The challenge will be to implement that ambition in ways that support innovation and avoid piling unrecoverable administrative costs on companies already managing complex technical and commercial risks.