CSRD Taxonomy Article 8 KPI disclosures

Article 8 of the EU Taxonomy Regulation requires undertakings that publish sustainability information under Articles 19a or 29a of the Accounting Directive to explain how and to what extent their activities are associated with environmentally sustainable economic activities. Commission Delegated Regulation (EU) 2021/2178 specifies the content, presentation, KPI methodology, and templates for those disclosures.

Use one reporting calendar and evidence model for ESRS and Article 8 reporting, while keeping their calculations separate. ESRS starts from material impacts, risks, and opportunities. Article 8 starts from Taxonomy-eligible and Taxonomy-aligned economic activities, the undertaking type, and the KPI templates in the Disclosures Delegated Act.

For non-financial undertakings, the Article 8 KPI pack is built around turnover, capital expenditure, and operating expenditure. Turnover compares Taxonomy-aligned net turnover with total net turnover. CapEx and OpEx compare the Taxonomy-aligned portion of the relevant expenditure base with the full denominator defined in the Disclosures Delegated Act.

Commission Delegated Regulation (EU) 2026/73 replaced the non-financial undertaking templates and introduced optional financial-materiality relief. For each KPI, a non-financial undertaking may omit eligibility and alignment assessment for economic activities whose cumulative turnover, CapEx, or OpEx is below 10% of that KPI's denominator. The omitted amount stays in the denominator and is reported separately as non-material; all activities for which the relief is used count toward the cumulative threshold.

The template control should trace each assessed economic activity to its code, monetary amount, proportion, environmental objective, alignment conclusion, and enabling or transitional category. Keep the detailed substantial-contribution, DNSH, and minimum-safeguards evidence in the screening file even where the simplified published template does not display every test as a separate column.

Treat the Article 8 disclosure as a data product before it becomes narrative in the sustainability statement. The control file should contain a row per economic activity and per KPI population, with a stable link to the accounting source, Taxonomy activity screening file, environmental objective, DNSH evidence, minimum safeguards assessment, calculation owner, and reviewer sign-off.

For group reporting, the record should preserve consolidation logic and avoid mixing entity-level eligibility screening with group-level KPI denominators. For financial undertakings, counterparty KPI inputs should be stored with source year, whether the data came from mandatory Article 8 reporting or another allowed basis, and the weighting method used in the relevant KPI.

EFRAG's Article 8 XBRL Taxonomy is technical advice that transposes the Disclosures Delegated Act into machine-readable concepts. It does not change the legal content of Article 8 disclosures and is not, by itself, a filing rule. ESMA confirms that sustainability reporting does not have to be marked up until the Commission adopts marking-up rules through a delegated regulation. Directive (EU) 2026/470 instructs Member States to transpose the same express rule into Article 29d by 19 March 2027.

Digital readiness should focus on traceability without presenting a draft taxonomy as a current filing obligation. The published table, calculation file, and eventual tagged fact should point to the same activity, amount, unit, period, objective, and dimensional breakdown. EFRAG designed its Article 8 taxonomy as a closed taxonomy, but the authoritative taxonomy and tagging rules must be checked in the applicable version of Delegated Regulation (EU) 2019/815 once adopted.

Article 8 KPI evidence should be ready for the same assurance discipline as the sustainability statement. The reviewer needs to reperform the route from source data to eligibility, alignment, denominator, numerator, template cell, narrative explanation, and tagged fact without relying on undocumented management judgment.

Use one evidence index across finance, sustainability, legal, and reporting-system owners. Distinguish binding source requirements from EFRAG technical support, management estimates from source data, and ESRS narrative from Article 8 calculation outputs.