CSRD vs EU Taxonomy Article 8 where sustainability reporting and taxonomy KPIs meet
CSRD and ESRS govern the sustainability statement. EU Taxonomy Article 8 adds disclosures on how and to what extent covered undertakings' activities are associated with environmentally sustainable economic activities.
This comparison helps separate double-materiality reporting from taxonomy eligibility, alignment, KPI templates, and digital tagging work.
CSRD and EU Taxonomy Article 8 are connected but not interchangeable. CSRD reporters prepare an ESRS sustainability statement. Article 8 requires covered undertakings to disclose how and to what extent their activities are associated with environmentally sustainable economic activities. A taxonomy-eligible activity is described in a delegated act; a must also make a substantial contribution, do no significant harm to the other objectives, meet minimum safeguards, and satisfy the applicable technical screening criteria. Delegated Regulation (EU) 2026/73 now amends the Article 8 content, templates, and assessment rules.
Comparison matrix
CSRD vs EU Taxonomy Article 8 disclosures
Read the EU Taxonomy side as the Article 8 disclosure and KPI layer, not as a replacement for CSRD or ESRS reporting.
CSRD amends the Accounting Directive and requires in-scope undertakings to report sustainability information according to ESRS in a dedicated section of the management report.
Second framework
EU Taxonomy Article 8
Article 8 requires disclosure of how and to what extent activities are associated with environmentally sustainable economic activities; Delegated Regulation (EU) 2021/2178 specifies content, presentation, and KPI methodology.
CSRD scope follows the Accounting Directive as amended. Directive (EU) 2026/470 narrows the main Articles 19a and 29a scope from financial years beginning in 2027 to undertakings and parent groups exceeding EUR 450 million net turnover and 1,000 average employees; the resulting scope decision helps determine whether Article 8 disclosures enter the reporting package.
Identifies the CSRD reporting categories referenced by ESRS adoption.
large undertakings, small and medium-sized undertakings
Article 8 applies to undertakings subject to the obligation to publish sustainability information under Articles 19a or 29a of the Accounting Directive, and asks for information on how and to what extent activities are associated with environmentally sustainable economic activities.
States that the Article 8 disclosure obligation is specified for undertakings subject to Articles 19a or 29a.
undertakings subject to Articles 19a or 29a
Start with the CSRD or Accounting Directive reporting obligation, then decide which Article 8 template and KPI rules apply. Do not run Article 8 as a standalone voluntary green-claim test.
Explains that EU law requires covered companies to disclose sustainability risks, opportunities, and impacts, and that CSRD companies report according to ESRS.
Companies subject to the CSRD have to report according to European Sustainability Reporting Standards
Adopts ESRS and states that the standards specify sustainability information to disclose under the Accounting Directive as amended by CSRD.
impacts on sustainability matters and how sustainability matters affect
Article 8 reporting explains taxonomy eligibility and alignment by reference to environmentally sustainable economic activities and the prescribed KPI framework.
Specifies the content, presentation, and methodology for Article 8 taxonomy disclosures.
content and presentation of information to be disclosed
Do not treat a as a complete ESRS disclosure. ESRS still requires materiality-based narrative, metrics, policies, actions, targets, and basis-of-preparation disclosures where applicable.
Eligibility means an activity is described in the relevant taxonomy delegated acts. Alignment requires the activity to contribute substantially to at least one of the six environmental objectives, do no significant harm to the others, meet Article 18 minimum safeguards, and comply with the applicable technical screening criteria.
Requires disclosure of which economic activities are Taxonomy-aligned and KPI breakdowns by environmental objective for non-financial undertakings.
which of their economic activities are Taxonomy-aligned
Keep two audit trails: one for ESRS materiality and one for activity eligibility, each alignment condition, KPI calculations, and template presentation. Eligibility alone is not alignment, and neither conclusion determines ESRS materiality.
ESRS metrics depend on the relevant topical standard and materiality conclusions. Some ESRS taxonomy datapoints also identify relationships between significant CapEx or OpEx disclosures and taxonomy KPI or CapEx-plan information.
Identifies ESRS taxonomy elements that relate significant CapEx or OpEx disclosures to taxonomy KPI or CapEx-plan information.
relationship of significant CapEx and OpEx
For non-financial undertakings, Article 8 KPIs cover turnover, capital expenditure, and operating expenditure. Under Delegated Regulation (EU) 2026/73, an undertaking may omit activity assessment where cumulative turnover or CapEx is below 10% of the relevant KPI denominator. It may omit the OpEx assessment when OpEx is not material to its business model, subject to the regulation's disclosure conditions. Financial undertakings use separate KPI methods and templates.
Binding amendment introducing the 10% turnover and CapEx assessment thresholds, the conditional OpEx omission, and revised Article 8 templates.
Finance, sustainability, and consolidation teams should reconcile taxonomy KPI inputs to ESRS financial links and document any 2026 omission used. An omitted immaterial activity is not thereby classified as ineligible or non-aligned.
CSRD evidence should support the ESRS basis of preparation, materiality assessment, value-chain boundaries, policies, actions, targets, and sustainability statement disclosures.
EFRAG project page identifies IG 1 Materiality Assessment as implementation guidance related to ESRS adopted in Delegated Regulation (EU) 2023/2772.
EFRAG IG 1 Materiality Assessment
Article 8 evidence should support activity mapping, taxonomy eligibility and alignment conclusions, KPI numerator and denominator calculations, templates, qualitative explanations, and any CapEx plan treatment.
Explains that Article 8 XBRL taxonomy digitises templates and disclosures from the Disclosures Delegated Act.
transposing the Article 8 disclosure requirements into machine-readable format
A shared data room can work, but each source record should say whether it supports an ESRS disclosure, an Article 8 KPI, or both. This prevents a taxonomy calculation from being over-read as a materiality conclusion.
CSRD introduced electronic-format requirements and markup obligations for sustainability reporting in the management report, but markup is not required until the marking-up rules are adopted.
Current Article 29d source for the electronic reporting format and the rule that sustainability markup is not required until the marking-up rules are adopted.
undertakings shall not be required to mark up their sustainability reporting
Delegated Regulation (EU) 2026/73 applies from 1 January 2026. For a financial year starting during 2025, an undertaking may instead use the delegated regulations as they stood on 31 December 2025. Article 8 disclosures remain part of the digital sustainability reporting package and use a content model distinct from ESRS disclosures.
Use CSRD and ESRS to decide what the sustainability statement must explain about material sustainability matters, including impacts, risks, opportunities, governance, strategy, policies, actions, targets, and metrics.
Supports the CSRD/ESRS reporting obligation and public purpose of sustainability reporting.
evaluate the sustainability performance of companies
Use Article 8 to decide which taxonomy activities, KPIs, templates, methodology, and qualitative explanations must be included for the undertaking type.
Supports the taxonomy KPI, template, and methodology decision rule.
content and presentation of the information required by Article 8
Scope the CSRD reporting obligation, complete the ESRS materiality and disclosure analysis, run the Article 8 KPI workstream for the same reporting perimeter where required, and reconcile overlaps before assurance and digital tagging.
Supports using ESRS as the standard-set for CSRD sustainability statement content.
sustainability reporting standards
Scope boundary
CSRD and ESRS
CSRD scope follows the Accounting Directive as amended. Directive (EU) 2026/470 narrows the main Articles 19a and 29a scope from financial years beginning in 2027 to undertakings and parent groups exceeding EUR 450 million net turnover and 1,000 average employees; the resulting scope decision helps determine whether Article 8 disclosures enter the reporting package.
Identifies the CSRD reporting categories referenced by ESRS adoption.
large undertakings, small and medium-sized undertakings
EU Taxonomy Article 8
Article 8 applies to undertakings subject to the obligation to publish sustainability information under Articles 19a or 29a of the Accounting Directive, and asks for information on how and to what extent activities are associated with environmentally sustainable economic activities.
States that the Article 8 disclosure obligation is specified for undertakings subject to Articles 19a or 29a.
undertakings subject to Articles 19a or 29a
Operational implication
Start with the CSRD or Accounting Directive reporting obligation, then decide which Article 8 template and KPI rules apply. Do not run Article 8 as a standalone voluntary green-claim test.
Explains that EU law requires covered companies to disclose sustainability risks, opportunities, and impacts, and that CSRD companies report according to ESRS.
Companies subject to the CSRD have to report according to European Sustainability Reporting Standards
Adopts ESRS and states that the standards specify sustainability information to disclose under the Accounting Directive as amended by CSRD.
impacts on sustainability matters and how sustainability matters affect
EU Taxonomy Article 8
Article 8 reporting explains taxonomy eligibility and alignment by reference to environmentally sustainable economic activities and the prescribed KPI framework.
Specifies the content, presentation, and methodology for Article 8 taxonomy disclosures.
content and presentation of information to be disclosed
Operational implication
Do not treat a as a complete ESRS disclosure. ESRS still requires materiality-based narrative, metrics, policies, actions, targets, and basis-of-preparation disclosures where applicable.
Eligibility means an activity is described in the relevant taxonomy delegated acts. Alignment requires the activity to contribute substantially to at least one of the six environmental objectives, do no significant harm to the others, meet Article 18 minimum safeguards, and comply with the applicable technical screening criteria.
Requires disclosure of which economic activities are Taxonomy-aligned and KPI breakdowns by environmental objective for non-financial undertakings.
which of their economic activities are Taxonomy-aligned
Operational implication
Keep two audit trails: one for ESRS materiality and one for activity eligibility, each alignment condition, KPI calculations, and template presentation. Eligibility alone is not alignment, and neither conclusion determines ESRS materiality.
ESRS datapoints explain relationships and differences between ESRS CapEx or OpEx disclosures and Taxonomy KPI disclosures.
differences between significant OpEx and CapEx disclosed under ESRS E1
Core obligations
CSRD and ESRS
ESRS metrics depend on the relevant topical standard and materiality conclusions. Some ESRS taxonomy datapoints also identify relationships between significant CapEx or OpEx disclosures and taxonomy KPI or CapEx-plan information.
Identifies ESRS taxonomy elements that relate significant CapEx or OpEx disclosures to taxonomy KPI or CapEx-plan information.
relationship of significant CapEx and OpEx
EU Taxonomy Article 8
For non-financial undertakings, Article 8 KPIs cover turnover, capital expenditure, and operating expenditure. Under Delegated Regulation (EU) 2026/73, an undertaking may omit activity assessment where cumulative turnover or CapEx is below 10% of the relevant KPI denominator. It may omit the OpEx assessment when OpEx is not material to its business model, subject to the regulation's disclosure conditions. Financial undertakings use separate KPI methods and templates.
Binding amendment introducing the 10% turnover and CapEx assessment thresholds, the conditional OpEx omission, and revised Article 8 templates.
Operational implication
Finance, sustainability, and consolidation teams should reconcile taxonomy KPI inputs to ESRS financial links and document any 2026 omission used. An omitted immaterial activity is not thereby classified as ineligible or non-aligned.
Supports separate KPI calculation and presentation requirements for Article 8 disclosures.
methodology to comply with that disclosure
Evidence record
CSRD and ESRS
CSRD evidence should support the ESRS basis of preparation, materiality assessment, value-chain boundaries, policies, actions, targets, and sustainability statement disclosures.
EFRAG project page identifies IG 1 Materiality Assessment as implementation guidance related to ESRS adopted in Delegated Regulation (EU) 2023/2772.
EFRAG IG 1 Materiality Assessment
EU Taxonomy Article 8
Article 8 evidence should support activity mapping, taxonomy eligibility and alignment conclusions, KPI numerator and denominator calculations, templates, qualitative explanations, and any CapEx plan treatment.
Explains that Article 8 XBRL taxonomy digitises templates and disclosures from the Disclosures Delegated Act.
transposing the Article 8 disclosure requirements into machine-readable format
Operational implication
A shared data room can work, but each source record should say whether it supports an ESRS disclosure, an Article 8 KPI, or both. This prevents a taxonomy calculation from being over-read as a materiality conclusion.
Supports keeping Article 8 evidence tied to taxonomy KPI content and methodology.
calculated as the numerator divided by the denominator
Reporting period and digital format
CSRD and ESRS
CSRD introduced electronic-format requirements and markup obligations for sustainability reporting in the management report, but markup is not required until the marking-up rules are adopted.
Current Article 29d source for the electronic reporting format and the rule that sustainability markup is not required until the marking-up rules are adopted.
undertakings shall not be required to mark up their sustainability reporting
EU Taxonomy Article 8
Delegated Regulation (EU) 2026/73 applies from 1 January 2026. For a financial year starting during 2025, an undertaking may instead use the delegated regulations as they stood on 31 December 2025. Article 8 disclosures remain part of the digital sustainability reporting package and use a content model distinct from ESRS disclosures.
Provides the separate Article 8 digital taxonomy reference for taxonomy disclosure content.
Article 8 XBRL Taxonomy
Practical sequence
CSRD and ESRS
Use CSRD and ESRS to decide what the sustainability statement must explain about material sustainability matters, including impacts, risks, opportunities, governance, strategy, policies, actions, targets, and metrics.
Supports the CSRD/ESRS reporting obligation and public purpose of sustainability reporting.
evaluate the sustainability performance of companies
EU Taxonomy Article 8
Use Article 8 to decide which taxonomy activities, KPIs, templates, methodology, and qualitative explanations must be included for the undertaking type.
Supports the taxonomy KPI, template, and methodology decision rule.
content and presentation of the information required by Article 8
Operational implication
Scope the CSRD reporting obligation, complete the ESRS materiality and disclosure analysis, run the Article 8 KPI workstream for the same reporting perimeter where required, and reconcile overlaps before assurance and digital tagging.
Supports using ESRS as the standard-set for CSRD sustainability statement content.
sustainability reporting standards
Practical decision rule
Practical decision rule
Confirm whether Articles 19a or 29a create the reporting obligation and whether the undertaking uses non-financial or financial Article 8 templates.
Keep the ESRS materiality decision separate from activity eligibility, every alignment condition, and Article 8 numerator and denominator calculations.
Record the financial year and the Taxonomy rule set used, including any assessment omission, then reconcile shared figures before assurance.
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When this comparison is useful
This page is relevant when the same reporting project contains both ESRS sustainability disclosures and EU Taxonomy Article 8 key performance indicator (KPI) disclosures. The overlap is real: Article 8 disclosures sit inside sustainability reporting and are part of the digital reporting package, but the legal tests and templates are different.
ESRS materiality tells the company which sustainability matters and disclosures are material. Article 8 tells covered undertakings how to report activity eligibility, alignment, and KPIs under the Taxonomy rules. Start Article 8 by mapping activities to the delegated acts, then test each alignment condition and calculate the applicable KPI.
For reporting under the 2026 amendments, document whether the 10% turnover or CapEx assessment threshold is used and whether OpEx is immaterial to the business model. Keep the omitted amount, denominator, rationale, and required accompanying disclosure so reviewers can distinguish an assessment omission from a negative eligibility or alignment result.
Keep the ESRS materiality assessment separate from the taxonomy activity-mapping file.
For each activity, preserve the delegated-act code or description used for eligibility, the environmental objective, the substantial-contribution test, every applicable do-no-significant-harm test, the minimum-safeguards assessment, and the evidence date.
Reconcile CapEx and OpEx references where ESRS climate disclosures and Article 8 KPI disclosures use related finance data.
Confirm whether the undertaking is non-financial or financial before selecting Article 8 KPI templates.
Treat XBRL tagging as a reporting-output step, not as the source of the legal disclosure obligation.
Reassess eligibility and alignment when an activity, delegated-act criterion, evidence set, acquisition or disposal, reporting boundary, or KPI denominator changes.
Current binding amendment for Article 8 assessment thresholds, OpEx treatment, templates, and application timing.
Recommended next step
Separate ESRS disclosures from Article 8 KPI work
Map CSRD scope, ESRS materiality, taxonomy activity alignment, KPI calculations, and XBRL tagging before the reporting package goes into assurance or publication.
Current amendment to the Disclosures, Climate, and Environmental Delegated Acts, including 2026 assessment thresholds, OpEx treatment, templates, and timing.
Current binding amendment for Article 8 assessment thresholds, OpEx treatment, templates, and application timing.
Binding amendment introducing the 10% turnover and CapEx assessment thresholds, the conditional OpEx omission, and revised Article 8 templates.
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Binding source for the 1 January 2026 application date and the option for financial years starting in 2025.
European Commission overview used for the CSRD purpose statement and ESRS reporting requirement.
Explains that EU law requires covered companies to disclose sustainability risks, opportunities, and impacts, and that CSRD companies report according to ESRS.
Supports the CSRD/ESRS reporting obligation and public purpose of sustainability reporting.
"Companies subject to the CSRD have to report according to European Sustainability Reporting Standards"
More quoted passages
"evaluate the sustainability performance of companies"
Current legal source for the amended CSRD scope used in this comparison.
Current Article 29d source for the electronic reporting format and the rule that sustainability markup is not required until the marking-up rules are adopted.
"Directive (EU) 2026/470"
More quoted passages
"undertakings shall not be required to mark up their sustainability reporting"