Taxonomy Article 8 KPIs under CSRD and ESRS

Article 8 of the EU Taxonomy Regulation requires undertakings in the scope of the relevant Accounting Directive sustainability-reporting provisions to disclose how and to what extent their activities are associated with environmentally sustainable economic activities. For CSRD reporters, those disclosures are part of sustainability reporting rather than a separate marketing claim.

For a non-financial undertaking, the core Article 8 KPI work is to calculate and present the Taxonomy-aligned share of turnover, capital expenditure (CapEx), and operating expenditure (OpEx) using the Taxonomy disclosure regulation and templates.

Commission Delegated Regulation (EU) 2026/73 permits specified eligibility and alignment assessments to be omitted below separate 10% turnover, CapEx or OpEx thresholds, and permits all OpEx assessment to be omitted when OpEx is not material to the business model. Amounts covered by those derogations must be reported separately as non-material; where all OpEx assessment is omitted, the undertaking must disclose the total OpEx denominator and explain why OpEx is not material to its business model.

The CSRD connection is that the sustainability report includes those Article 8 disclosures. Directive (EU) 2026/470 states that marking-up is not required until the relevant rules are adopted through the European Single Electronic Format regulation.

They are related to ESRS reporting, but they are not ESRS datapoints calculated through ESRS double materiality. ESRS sets the sustainability-reporting baseline for CSRD reports, while Article 8 KPIs come from the EU Taxonomy disclosure framework and its delegated regulation.

The practical consequence is that the sustainability reporting owner should align presentation, controls, sign-off, and assurance readiness across ESRS and Article 8, but should not use ESRS materiality to omit or redesign required Article 8 KPI templates. Apply the separate Article 8 derogations where their conditions are met. For activities assessed for alignment, first classify each activity as a Taxonomy-eligible economic activity, then test whether it meets the criteria for a Taxonomy-aligned economic activity: substantial contribution, do-no-significant-harm criteria, minimum safeguards and technical screening criteria.

The 2024 Article 8 XBRL taxonomy is a digital representation of the Article 8 disclosure templates and related information requirements then in force. EFRAG states that it transposes the disclosure requirements into machine-readable format as technical support; it does not change the underlying EU Taxonomy KPI rules or, by itself, create a filing duty. Commission Delegated Regulation (EU) 2026/73 later replaced or amended several of those templates.

If digital tagging becomes applicable, use the taxonomy adopted for the reporting period. Prepare one mapping from source finance and activity data into the applicable Article 8 KPI templates, and another from the final disclosure tables and narrative context into the applicable taxonomy elements.

Keep evidence that proves the published KPI values, not just evidence that the report was reviewed. Article 8 KPIs are percentage disclosures built from financial amounts, Taxonomy activity assessments, and template rules, so the retained file should let a decision owner or assurance provider retrace the calculation.

Select the Article 8 annexes for the reporting entity before calculating KPIs. Keep non-financial undertaking turnover, CapEx, and OpEx workpapers separate from the green asset ratio and other templates for credit institutions, asset managers, investment firms, or insurers.

The main risk is mixing three different layers: the legal KPI obligation, the ESRS sustainability-statement process, and the XBRL tagging layer. When those layers are merged into one generic checklist, teams can publish a plausible-looking sustainability section without a traceable KPI calculation or a reliable digital-tagging map.

Keep the layers distinct: Article 8 determines the KPI content and templates, CSRD and ESRS determine the sustainability-reporting package and governance context, and the applicable digital taxonomy supports machine-readable tagging of the final disclosures.