EU Taxonomy Activity Eligibility Workflow

The first workflow control is a definition check. Under the Disclosures Delegated Act, a Taxonomy-eligible economic activity is an activity described in delegated acts adopted for the Taxonomy environmental objectives, regardless of whether it meets any or all technical screening criteria in those delegated acts.

That means the eligibility record should never say that a mapped activity is sustainable, aligned, DNSH-compliant, or minimum-safeguards compliant unless a separate alignment assessment supports that conclusion.

Run eligibility at the level of economic activities, not at the level of business units, brands, suppliers, or broad product families. The activity record should show the resources, process, and output that produce goods or services, then match that activity to the relevant delegated-act description.

NACE codes can help users navigate the Taxonomy, but they are not the final eligibility test. If a NACE code is broader than the delegated-act activity description, the description prevails; if the activity fits the description even without a listed NACE code, it can still be eligible.

After the activity match is documented, classify which disclosure metric the activity can affect. For non-financial undertakings, Article 8 reporting uses the proportions of turnover, capital expenditure, and operating expenditure associated with Taxonomy-eligible and Taxonomy-aligned economic activities.

For financial undertakings, eligibility work depends on the applicable financial-undertaking templates and the available information from counterparties, assets, use-of-proceeds instruments, or underwriting activity. The workflow should record the source of the counterparty or asset-level eligibility data rather than treating a financial exposure as eligible by label alone.

The eligibility file should be reviewable without reconstructing the whole analysis. Each row should show the source, the activity description match, the KPI impact, the owner, and the reason the claim is limited to eligibility or escalated into alignment testing.

Stop the workflow when the public wording is broader than the source, when a NACE code is being used as the only proof, when voluntary information is mixed with mandatory disclosures without explanation, or when a draft or advisory source is treated as a binding delegated act.