Green Bond Framework Template (ICMA GBP, EuGB)
Issuer green bond framework: strategy, use of proceeds, eligible categories, project selection, management of proceeds, allocation and impact reporting, external review, EuGB
How to use: Use it before a first green bond or green loan issue, and update it before each new programme. Fill the eligible categories with measurable criteria and the EuGB decision first. The main pitfall is claiming the whole project's impact while the bond financed only part of it.
Preview
Green Bond Framework: [Issuer name]
Issuer framework for green bonds and other green debt: rationale, use of proceeds, process for project evaluation and selection, management of proceeds, reporting, and external review. Structure aligned with the four core components and two key recommendations of the ICMA Green Bond Principles (June 2025 edition, voluntary), with a section for issuers that also want to use the "European Green Bond" (EuGB) designation under Regulation (EU) 2023/2631, which applies from 2024-12-21. Replace every
[bracketed]value and every row marked Example. This is a documentation format, not legal, financial or investment advice: check the current official text and a qualified professional.
Document control
| Field | Value |
|---|---|
| Document ID | [GBF-NNN] Example: GBF-001 |
| Issuer | [Legal entity and guarantor] Example: Calderwick Utilities plc |
| Instruments covered | [Senior bonds, private placements, green loans, commercial paper] |
| Alignment | [ICMA GBP June 2025 / plus EuGB Regulation (EU) 2023/2631] |
| External reviewer | [Name, type of review] |
| Version | [1.0] |
| Status | [Draft / Approved / Published] |
| Owner | [@head-of-treasury] |
| Approvers/reviewers | [@cfo], [@head-of-sustainability], [@legal], [@board-or-committee] |
| Publication URL | [Investor relations page] |
| Last updated | YYYY-MM-DD |
| Classification | [Public once approved] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| Head of treasury | [@name] | [Prepared] | YYYY-MM-DD |
| Head of sustainability | [@name] | [Reviewed] | YYYY-MM-DD |
| CFO or board committee | [@name] | [Approved] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | Draft for external review |
| 1.0 | YYYY-MM-DD | [@name] | Example: Published with second party opinion |
1. Issuer overview and sustainability strategy
Describe the business, its main environmental impacts, the climate and environmental targets, and how eligible projects advance them. Link the transition plan and the latest emissions inventory.
Example: Calderwick Utilities operates electricity distribution and water networks. Its targets are a [percentage] reduction in Scope 1 and 2 emissions by [year] against [base year], connection of [MW] of renewable generation, and a [percentage] reduction in water leakage. Green bonds finance network investment that delivers these targets.
2. Use of proceeds
An amount equal to the net proceeds of each green bond will be allocated to finance or refinance eligible green projects defined in section 3. Refinancing covers capital expenditure incurred in the [three] years before issuance and operating expenditure in the [one] year before issuance. The issuer will disclose the expected share of refinancing for each issue.
Exclusions: [fossil fuel generation, extraction or transport, nuclear, activities with severe controversies, other exclusions].
3. Eligible green project categories
| Category ID | GBP category | Eligibility criteria | Environmental objective | EU Taxonomy activity (if EuGB) |
|---|---|---|---|---|
| GBF-C1 | Renewable energy | Grid connections and reinforcement for wind, solar and storage | Climate change mitigation | [Activity number and name] |
| GBF-C2 | Energy efficiency | Building renovation meeting [threshold] primary energy reduction | Climate change mitigation | [Activity] |
| GBF-C3 | Clean transportation | Public EV charging infrastructure | Climate change mitigation | [Activity] |
| GBF-C4 | Sustainable water and wastewater management | Leakage reduction with [threshold] net improvement in energy or water efficiency | Water and marine resources | [Activity] |
4. Project evaluation and selection
A Green Finance Committee chaired by [the CFO] with [treasury, sustainability, engineering, legal] members meets [twice a year] to:
- Review candidate projects against section 3 criteria and exclusions.
- Confirm management of environmental and social risks, including minimum safeguards and, for EuGB, do-no-significant-harm evidence.
- Approve the eligible project register and remove projects that no longer qualify, replacing them as soon as practicable.
- Approve allocation and impact reports before publication.
5. Management of proceeds
Net proceeds are tracked in [a sub-ledger or register] maintained by treasury and reconciled [quarterly] to the eligible project register. The issuer intends to allocate proceeds within [24] months of issuance. Unallocated proceeds are held in [cash, deposits or money market instruments] in line with the treasury policy and exclusions. Allocation is reviewed by [internal audit or the external auditor] annually.
6. Reporting
Allocation report (annual until full allocation, then on material change). Example for a EUR 500.0 million bond, net proceeds EUR 497.5 million after EUR 2.5 million costs, as at 2028-12-31, EUR millions:
| Category | Allocated | Share of allocated |
|---|---|---|
| GBF-C1 Renewable energy grid connections | 210.0 | 45.1% |
| GBF-C2 Energy efficiency in buildings | 95.5 | 20.5% |
| GBF-C3 Clean transportation | 120.0 | 25.8% |
| GBF-C4 Sustainable water management | 40.0 | 8.6% |
| Total allocated | 465.5 | 100.0% |
| Unallocated | 32.0 | |
| Net proceeds | 497.5 |
Allocated share is 465.5 / 497.5 = 93.6% of net proceeds; refinancing is EUR 180.0 million, 38.7% of the allocated amount.
Impact report, with methods, baselines and the share attributable to the bond. Example for GBF-C1: 640 MW of renewable capacity connected, assumed 30% capacity factor, giving 640 x 0.30 x 8,760 = 1,681,920 MWh a year; at an assumed grid factor of 0.25 tCO2e per MWh, 420,480 tCO2e a year avoided, of which the bond financed 210 / 350 = 60%, so 252,288 tCO2e is attributed. Use the ICMA Harmonised Framework for Impact Reporting for core indicators and state every assumption.
7. External review
| Review | Timing | Provider | Status |
|---|---|---|---|
| Second party opinion on this framework | Before first issue | [Reviewer] | [Planned / Published] |
| Verification of allocation | Annually until full allocation | [Auditor or reviewer] | |
| EuGB pre-issuance review of factsheet | Before issue, EuGB only | [ESMA-registered reviewer] | |
| EuGB post-issuance review of allocation report | After full allocation, EuGB only | [ESMA-registered reviewer] |
Since 2026-06-21 external reviewers for EuGB must be registered with ESMA; check the register on the ESMA website before appointment.
8. European Green Bond designation (optional)
| Requirement under Regulation (EU) 2023/2631 | Issuer response |
|---|---|
| Proceeds allocated to activities aligned with the EU Taxonomy, with a flexibility pocket of up to 15% for activities without technical screening criteria in force, subject to conditions (Art. 5) | Example: 440.0 / 497.5 = 88.4% planned taxonomy-aligned |
| Factsheet in the Annex I format, with pre-issuance review (Art. 10) | [Reference] |
| Allocation reports every 12 months until full allocation, with post-issuance review after full allocation (Art. 11) | [Reference] |
| Impact report at least once during the bond's life after full allocation (Art. 12) | [Reference] |
| Publication on the issuer website and notification to the competent authority and ESMA (Art. 15) | [Reference] |
| Prospectus requirements where a prospectus is required | [Reference] |
Optional disclosure templates also exist for bonds marketed as environmentally sustainable or sustainability-linked that do not use the EuGB designation; check the delegated acts.
9. Glossary and references
| Term | Meaning in this framework |
|---|---|
| Eligible green project | Project, asset, expenditure or activity meeting section 3 criteria |
| Net proceeds | Amount raised less issuance costs |
| Look-back period | Period before issuance whose spending can be refinanced |
| Second party opinion | Independent assessment of the framework's alignment with the Principles |
| Flexibility pocket | Share of EuGB proceeds that may go to activities without taxonomy criteria in force |
| Reference | Version or date | URL |
|---|---|---|
| ICMA Green Bond Principles | June 2025 | https://www.icmagroup.org/green-bond-principles-gbp/ |
| ICMA Harmonised Framework for Impact Reporting | Check current edition | https://www.icmagroup.org/sustainable-finance/ |
| Regulation (EU) 2023/2631 on European Green Bonds | OJ 2023-11-30, applies from 2024-12-21 | https://eur-lex.europa.eu/eli/reg/2023/2631/oj/eng |
| ESMA, External reviewers of European Green Bonds | Register updated 2026-10-16 | https://www.esma.europa.eu/esmas-activities/investors-and-issuers/external-reviewers-european-green-bonds |
Standard and licence note
Structure aligned with the ICMA Green Bond Principles (June 2025), which are voluntary guidelines published by the International Capital Market Association and summarised here in original words, and based on Regulation (EU) 2023/2631, cited by article number only. No text from ICMA publications is reproduced. Check the current edition of the Principles, the Official Journal text and ESMA guidance before use. Calderwick Utilities and all figures are fictional. The text is original and is not legal, financial or investment advice. Template licence: MIT.
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