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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

Finance, Investment & AccountingStandardICMA Green Bond Principles (June 2025); Regulation (EU) 2023/2631greenbondframework

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

FieldValue
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 updatedYYYY-MM-DD
Classification[Public once approved]

Approvals

RoleNameDecisionDate
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

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]Draft for external review
1.0YYYY-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 IDGBP categoryEligibility criteriaEnvironmental objectiveEU Taxonomy activity (if EuGB)
GBF-C1Renewable energyGrid connections and reinforcement for wind, solar and storageClimate change mitigation[Activity number and name]
GBF-C2Energy efficiencyBuilding renovation meeting [threshold] primary energy reductionClimate change mitigation[Activity]
GBF-C3Clean transportationPublic EV charging infrastructureClimate change mitigation[Activity]
GBF-C4Sustainable water and wastewater managementLeakage reduction with [threshold] net improvement in energy or water efficiencyWater 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:

  1. Review candidate projects against section 3 criteria and exclusions.
  2. Confirm management of environmental and social risks, including minimum safeguards and, for EuGB, do-no-significant-harm evidence.
  3. Approve the eligible project register and remove projects that no longer qualify, replacing them as soon as practicable.
  4. 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:

CategoryAllocatedShare of allocated
GBF-C1 Renewable energy grid connections210.045.1%
GBF-C2 Energy efficiency in buildings95.520.5%
GBF-C3 Clean transportation120.025.8%
GBF-C4 Sustainable water management40.08.6%
Total allocated465.5100.0%
Unallocated32.0
Net proceeds497.5

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

ReviewTimingProviderStatus
Second party opinion on this frameworkBefore first issue[Reviewer][Planned / Published]
Verification of allocationAnnually until full allocation[Auditor or reviewer]
EuGB pre-issuance review of factsheetBefore issue, EuGB only[ESMA-registered reviewer]
EuGB post-issuance review of allocation reportAfter 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) 2023/2631Issuer 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

TermMeaning in this framework
Eligible green projectProject, asset, expenditure or activity meeting section 3 criteria
Net proceedsAmount raised less issuance costs
Look-back periodPeriod before issuance whose spending can be refinanced
Second party opinionIndependent assessment of the framework's alignment with the Principles
Flexibility pocketShare of EuGB proceeds that may go to activities without taxonomy criteria in force
ReferenceVersion or dateURL
ICMA Green Bond PrinciplesJune 2025https://www.icmagroup.org/green-bond-principles-gbp/
ICMA Harmonised Framework for Impact ReportingCheck current editionhttps://www.icmagroup.org/sustainable-finance/
Regulation (EU) 2023/2631 on European Green BondsOJ 2023-11-30, applies from 2024-12-21https://eur-lex.europa.eu/eli/reg/2023/2631/oj/eng
ESMA, External reviewers of European Green BondsRegister updated 2026-10-16https://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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