--- title: "EU Taxonomy Applicability Test for Eligibility and Alignment" canonical_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/applicability-test" source_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/applicability-test" author: "Sorena AI" description: "Test EU Taxonomy applicability by separating Article 8 reporting scope, Taxonomy eligibility, Taxonomy alignment, DNSH, minimum safeguards, and KPI evidence." published_at: "2026-05-09" updated_at: "2026-05-27" keywords: - "EU Taxonomy applicability test" - "EU Taxonomy eligibility" - "EU Taxonomy alignment" - "Article 8 Taxonomy KPIs" - "turnover CapEx OpEx" - "DNSH" - "minimum safeguards" - "EU Taxonomy" - "Taxonomy Regulation" - "applicability test" - "Taxonomy eligibility" - "Taxonomy alignment" - "technical screening criteria" - "Article 8 KPIs" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Taxonomy Applicability Test for Eligibility and Alignment Test EU Taxonomy applicability by separating Article 8 reporting scope, Taxonomy eligibility, Taxonomy alignment, DNSH, minimum safeguards, and KPI evidence. *Taxonomy* *Applicability test* *EU* ## EU Taxonomy Applicability Test Decide whether an undertaking must report under Article 8, whether an activity is Taxonomy-eligible, and what evidence is needed before calling it Taxonomy-aligned. The test separates legal reporting scope from activity mapping, technical screening criteria, DNSH, minimum safeguards, and KPI workpapers. An EU Taxonomy applicability decision should not start with a generic sustainability label. Start with the reporting undertaking and the economic activity, then test Article 8 reporting scope, whether the activity is described in the delegated acts, and whether the evidence supports Taxonomy alignment under Article 3. ## Step 1: decide whether Article 8 reporting is in scope The Taxonomy Regulation links undertaking-level disclosure to entities that publish non-financial information under Articles 19a or 29a of Directive 2013/34/EU. For those undertakings, Article 8 requires information on how and to what extent activities are associated with environmentally sustainable economic activities. Do not treat every company, asset, supplier, or project as an Article 8 reporter. First record the reporting entity, whether the test is for a non-financial or financial undertaking, and which disclosure template or KPI family applies under the Disclosures Delegated Act. - Record the legal entity or group that publishes the non-financial statement or consolidated non-financial statement. - Classify the reporter as a non-financial undertaking, asset manager, credit institution, investment firm, or insurance or reinsurance undertaking. - For non-financial undertakings, prepare turnover, capital expenditure, and operating expenditure KPI workpapers. - For financial undertakings, identify the applicable KPI methodology, including GAR or other sector-specific KPI treatment where relevant. Sources for this answer: - [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Primary source for Article 8 reporting scope and non-financial undertaking turnover, CapEx, and OpEx disclosure categories. - [Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Delegated act specifying content, presentation, templates, and KPI methodology for financial and non-financial undertakings. *Recommended next step* *Placement: after evidence section* ## Turn the Taxonomy applicability answer into KPI evidence Use the applicability result to separate Article 8 scope, eligibility, alignment, DNSH, minimum safeguards, and KPI workpapers before publishing Taxonomy claims. - [Open Research Copilot](/solutions/research-copilot.md): Answer EU Taxonomy implementation questions with cited source material. - [Discuss EU Taxonomy implementation](/contact.md): Review scope, activity mapping, KPI evidence, and next implementation steps with Sorena. ## Step 2: separate eligibility from alignment Eligibility is an activity-mapping question. Under the Disclosures Delegated Act, a Taxonomy-eligible economic activity is one described in delegated acts adopted under the environmental-objective articles, whether or not it meets the technical screening criteria. Alignment is a higher test. Under Article 3 of the Taxonomy Regulation, the activity must substantially contribute to at least one environmental objective, do no significant harm to the others, meet minimum safeguards, and comply with applicable technical screening criteria. - Map the revenue, asset, project, loan, exposure, or expenditure to a specific economic activity described in a delegated act. - Mark non-described activities as Taxonomy-non-eligible rather than forcing them into the closest activity label. - For each eligible activity, identify the environmental objective, delegated-act section, and whether the activity is transitional or enabling where the criteria say so. - Do not count an eligible activity as aligned until substantial contribution, DNSH, minimum safeguards, and technical screening evidence are complete. Sources for this answer: - [Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Defines Taxonomy-eligible, Taxonomy-non-eligible, and Taxonomy-aligned economic activities for disclosure purposes. - [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Primary source for the Article 3 criteria that must all be met before an activity qualifies as environmentally sustainable. - [European Commission EU Taxonomy for sustainable activities](https://finance.ec.europa.eu/sustainable-finance/tools-and-standards/eu-taxonomy-sustainable-activities_en?ref=sorena.io) - Commission hub page describing the Taxonomy as a common classification system for sustainable economic activities. ## Step 3: test the Article 3 alignment criteria The alignment file should read like a chain of proof. For each activity, cite the delegated-act criteria used for substantial contribution, then record the DNSH checks for the other environmental objectives and the minimum-safeguards assessment. DNSH is not a generic statement. Article 17 lists significant-harm concepts across climate mitigation, climate adaptation, water and marine resources, circular economy, pollution prevention and control, and biodiversity and ecosystems. Commission guidance on the Climate Delegated Act also warns that technical screening criteria can be reviewed and updated over time. - Substantial contribution evidence: delegated-act section, threshold or qualitative criterion, calculation, data owner, and reviewer. - DNSH evidence: objective-by-objective check, lifecycle consideration where relevant, and any required assessment or plan. - Minimum safeguards evidence: procedures aligned with OECD Guidelines, UN Guiding Principles, ILO fundamental principles and rights, and the International Bill of Human Rights. - Version evidence: delegated-act version, assessment date, criteria effective date, and trigger for reassessment when criteria change. Sources for this answer: - [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Primary source for Article 3, Article 17 DNSH, Article 18 minimum safeguards, and Article 19 technical screening criteria requirements. - [Commission Notice C/2023/267 on the Climate Delegated Act](https://eur-lex.europa.eu/eli/C/2023/267/oj/eng?ref=sorena.io) - Commission notice with implementation clarifications for Climate Delegated Act technical screening criteria and DNSH questions. - [Platform on Sustainable Finance Final Report on Minimum Safeguards](https://finance.ec.europa.eu/system/files/2022-10/221011-sustainable-finance-platform-finance-report-minimum-safeguards_en.pdf?ref=sorena.io) - Advisory report explaining how Article 18 minimum safeguards are assessed in practice; not a binding legal interpretation. ## Step 4: connect the answer to KPI calculations The applicability test should end in a reportable data decision, not only a legal memo. For non-financial undertakings, Article 8 and the Disclosures Delegated Act require the proportions of turnover, CapEx, and OpEx associated with environmentally sustainable activities, with the delegated templates and contextual information. For financial undertakings, the KPI package depends on the undertaking type. The Disclosures Delegated Act sets separate disclosure rules for asset managers, credit institutions, investment firms, and insurance or reinsurance undertakings, and it contains common rules such as exclusions for central governments, central banks, supranational issuers, derivatives, and certain non-reporting undertakings in financial KPI calculations. - Tie each KPI numerator item to the activity mapping and alignment evidence used for the same reporting period. - Keep non-eligible, eligible but not aligned, and aligned amounts separate so the templates do not overstate alignment. - For CapEx plans, keep management-body or delegated approval evidence, planned measures, expenditures, timing, and milestones. - For financial undertakings, document counterparty KPI data, exclusions, estimate methodology where allowed, and any separate disclosure of estimated alignment. Sources for this answer: - [Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Grounds KPI templates, financial-undertaking methodologies, common exclusions, reporting-period rules, and contextual disclosures. - [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Commission implementation FAQ for reporting Taxonomy-eligible and Taxonomy-aligned economic activities and assets under Article 8. ## Step 5: keep the decision defensible after publication A useful applicability record should let a reviewer move from the published KPI or claim back to the legal source, activity classification, screening evidence, data extract, and approval decision. That is especially important when a public statement says an activity is Taxonomy-aligned rather than merely eligible. Keep advisory material labeled correctly. Commission notices can help interpret and implement the delegated acts, while Platform reports and Technical Expert Group materials are useful context but should not be presented as binding law. - Decision output: in Article 8 scope, outside Article 8 scope, Taxonomy-non-eligible, eligible but not aligned, aligned, or unresolved pending legal review. - Evidence pack: source URL, quote, delegated-act section, activity mapping, technical screening calculation, DNSH support, minimum-safeguards record, KPI workbook, and approver. - Review trigger: new delegated act, amended technical screening criteria, changed activity facts, changed revenue or asset boundary, or new reporting guidance. - Publication control: verify that website copy, annual-report text, SFDR/product material, and investor decks do not blur eligibility with alignment. Sources for this answer: - [Commission Notice C/2023/267 on the Climate Delegated Act](https://eur-lex.europa.eu/eli/C/2023/267/oj/eng?ref=sorena.io) - Grounds the caveat that Commission FAQ replies assist implementation but do not extend rights or obligations or authoritatively interpret Union law. - [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Grounds the distinction between applicable legislation and FAQ-style implementation assistance for Article 8 disclosures. - [European Commission EU Taxonomy for sustainable activities](https://finance.ec.europa.eu/sustainable-finance/tools-and-standards/eu-taxonomy-sustainable-activities_en?ref=sorena.io) - Commission hub for current Taxonomy legislation, delegated acts, notices, FAQs, and tools that should be checked before publication. ## Primary sources - [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Primary source for the EU Taxonomy framework, Article 3 environmental sustainability criteria, Article 8 disclosures, environmental objectives, DNSH, minimum safeguards, and technical screening criteria rules. - Quote: "economic activity shall qualify as environmentally sustainable" - [Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Delegated act specifying Article 8 disclosure content, presentation, templates, undertaking categories, KPI methodologies, and Taxonomy eligibility and alignment definitions. - Quote: "Taxonomy-aligned economic activity" - [European Commission EU Taxonomy for sustainable activities](https://finance.ec.europa.eu/sustainable-finance/tools-and-standards/eu-taxonomy-sustainable-activities_en?ref=sorena.io) - Commission overview and navigation page for the Taxonomy framework, delegated acts, notices, FAQs, and tools. - Quote: "classification system that defines criteria" - [Commission Notice C/2023/267 on the Climate Delegated Act](https://eur-lex.europa.eu/eli/C/2023/267/oj/eng?ref=sorena.io) - Commission notice with implementation clarifications for technical screening criteria and DNSH under the Climate Delegated Act. - Quote: "facilitate the effective application" - [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Commission notice with FAQs on reporting Taxonomy-eligible and Taxonomy-aligned economic activities and assets under Article 8. - Quote: "Taxonomy-eligible and Taxonomy-aligned economic activities and assets" - [Platform on Sustainable Finance Final Report on Minimum Safeguards](https://finance.ec.europa.eu/system/files/2022-10/221011-sustainable-finance-platform-finance-report-minimum-safeguards_en.pdf?ref=sorena.io) - Advisory source for minimum-safeguards practice under Article 18; useful for evidence design but not a binding legal interpretation. - Quote: "procedures implemented by an undertaking" ## Related Topic Guides - [DNSH Appendix C under the EU Taxonomy: chemicals evidence FAQ](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md): Practical FAQ on EU Taxonomy DNSH Appendix C chemicals criteria, including SVHCs, CLP hazard classes, the 0.1% w/w threshold, suitable alternatives, and controlled conditions evidence. - [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md): cited FAQ on EU Taxonomy 2026 simplification, Regulation (EU) 2026/73, Article 8 reporting, DNSH evidence, and limits on unsupported claims. - [EU Taxonomy Activity Eligibility Workflow](/artifacts/eu/taxonomy-regulation/activity-eligibility-workflow.md): Build an EU Taxonomy activity eligibility workflow that maps economic activities to delegated-act descriptions before alignment, DNSH, and Article 8 KPI reporting. - [EU Taxonomy activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md): A practical FAQ on EU Taxonomy activity evidence packs: eligibility, alignment, DNSH, minimum safeguards, KPI traceability, and cited-source review records. - [EU Taxonomy Article 8 disclosure templates](/artifacts/eu/taxonomy-regulation/templates.md): cited EU Taxonomy templates for Article 8 reporting, covering non-financial KPIs, financial undertaking annexes, eligibility and alignment evidence, GAR inputs, and publication checks. - [EU Taxonomy Article 8 KPI disclosure workflow](/artifacts/eu/taxonomy-regulation/kpis-and-disclosure-workflow.md): cited workflow for EU Taxonomy Article 8 KPI disclosures, covering turnover, CapEx, OpEx, GAR dependencies, templates, contextual information, and publication checks. - [EU Taxonomy Article 8 Scope and Reporting Entities](/artifacts/eu/taxonomy-regulation/scope-and-reporting-entities.md): Determine which financial and non-financial undertakings report under EU Taxonomy Article 8, which annexes apply, and what evidence supports the reporting boundary. - [EU Taxonomy Article 8 Scope FAQ](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md): cited FAQ on EU Taxonomy Article 8 scope, including who reports, which KPI framework applies, and what evidence teams should retain. - [EU Taxonomy auditor evidence: what to keep for alignment review](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md): Practical FAQ on EU Taxonomy auditor evidence: what evidence supports eligibility, alignment, DNSH, minimum safeguards, and Article 8 KPI disclosures. - [EU Taxonomy CapEx Plan Evidence Workflow](/artifacts/eu/taxonomy-regulation/capex-plan-evidence-workflow.md): Build an EU Taxonomy CapEx plan evidence workflow for Article 8 CapEx KPI reporting, management-body approval, milestones, amendments, allocation, and restatement controls. - [EU Taxonomy CapEx Plan Evidence: Article 8 checklist](/artifacts/eu/taxonomy-regulation/capex-plan-evidence.md): Build evidence for EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2 and the Disclosures Delegated Act. - [EU Taxonomy CapEx Plans FAQ: Article 8 CapEx KPI](/artifacts/eu/taxonomy-regulation/faq/capex-plans.md): Practical FAQ on EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2, management-body approval, timing, activity-level evidence, and KPI restatement. - [EU Taxonomy compliance guide: eligibility, alignment and Article 8 KPIs](/artifacts/eu/taxonomy-regulation/compliance.md): Practical EU Taxonomy compliance guide for mapping eligible activities, testing alignment, collecting DNSH and minimum-safeguards evidence, and preparing Article 8 disclosures. - [EU Taxonomy deadlines and Article 8 compliance calendar](/artifacts/eu/taxonomy-regulation/deadlines-and-compliance-calendar.md): cited EU Taxonomy calendar for Article 8 reporting phases, environmental objective application dates, delegated-act updates, and evidence review gates. - [EU Taxonomy Delegated Act Change Tracker](/artifacts/eu/taxonomy-regulation/delegated-act-change-tracker.md): Track adopted and proposed EU Taxonomy delegated-act changes by source, status, affected criteria, Article 8 disclosure impact, owner, and evidence update. - [EU Taxonomy delegated act changes: what teams should check](/artifacts/eu/taxonomy-regulation/faq/delegated-act-changes.md): FAQ on handling EU Taxonomy delegated act changes: official source checks, application dates, affected criteria, disclosures, DNSH evidence, and review records. - [EU Taxonomy Delegated Acts Tracker](/artifacts/eu/taxonomy-regulation/delegated-acts-tracker.md): Track EU Taxonomy delegated acts by legal status, objective, reporting impact, activity scope, DNSH criteria, Article 8 disclosures, and owner follow-up. - [EU Taxonomy DNSH and Minimum Safeguards evidence guide](/artifacts/eu/taxonomy-regulation/dnsh-and-minimum-safeguards.md): cited guide to EU Taxonomy DNSH and minimum safeguards: Article 3 alignment gates, Article 17 significant harm, Article 18 safeguards, evidence records, and KPI controls. - [EU Taxonomy DNSH Appendix C: chemicals evidence guide](/artifacts/eu/taxonomy-regulation/dnsh-appendix-c.md): cited guide to EU Taxonomy DNSH Appendix C chemicals checks, including SVHC thresholds, alternatives, controlled conditions, and evidence records. - [EU Taxonomy Eligibility vs Alignment](/artifacts/eu/taxonomy-regulation/taxonomy-eligibility-vs-alignment.md): Compare EU Taxonomy eligibility and alignment under Article 8: what each term means, what evidence is needed, which KPIs are affected, and why eligibility is not proof of sustainability. - [EU Taxonomy Eligibility vs Alignment Explained](/artifacts/eu/taxonomy-regulation/taxonomy-eligibility-vs-alignment-explained.md): Explain EU Taxonomy eligibility and alignment under Article 8, the Disclosures Delegated Act, Article 3, technical screening criteria, DNSH, and safeguards. - [EU Taxonomy eligibility vs alignment: what is the difference?](/artifacts/eu/taxonomy-regulation/faq/eligibility-vs-alignment.md): Eligibility means an activity is covered by Taxonomy delegated acts; alignment means it also meets Article 3 conditions, technical screening criteria, DNSH, and minimum safeguards. - [EU Taxonomy FAQ: eligibility, alignment, DNSH, safeguards, and Article 8](/artifacts/eu/taxonomy-regulation/faq.md): EU Taxonomy FAQ hub for eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, Article 8 KPIs, delegated acts, and evidence records. - [EU Taxonomy Financial KPIs and Green Asset Ratio (GAR) FAQ](/artifacts/eu/taxonomy-regulation/faq/financial-kpis-and-gar.md): FAQ on EU Taxonomy Article 8 financial undertaking KPIs, credit institution Green Asset Ratio (GAR), reporting dates, exclusions, and qualitative disclosures. - [EU Taxonomy GAR and financial undertaking KPIs](/artifacts/eu/taxonomy-regulation/gar-and-financial-undertaking-kpis.md): cited guide to EU Taxonomy Article 8 financial undertaking KPIs, including GAR, asset manager KPIs, investment firm KPIs, insurance KPIs, exclusions, and reporting evidence. - [EU Taxonomy GAR KPI workflow for credit institutions](/artifacts/eu/taxonomy-regulation/gar-kpi-workflow.md): cited workflow for preparing EU Taxonomy Green Asset Ratio (GAR) KPI disclosures under Article 8 and the Disclosures Delegated Act. - [EU Taxonomy gas and nuclear activities: when can they align?](/artifacts/eu/taxonomy-regulation/faq/gas-and-nuclear-activities.md): Explain how the EU Taxonomy Complementary Climate Delegated Act treats specified gas and nuclear activities, alignment criteria, DNSH evidence, and separate disclosures. - [EU Taxonomy minimum safeguards FAQ: Article 18 evidence](/artifacts/eu/taxonomy-regulation/faq/minimum-safeguards.md): FAQ on EU Taxonomy minimum safeguards under Article 18: who must comply, which OECD, UNGP, ILO and human-rights evidence to keep, and common reporting mistakes. - [EU Taxonomy Minimum Safeguards: Article 18 and evidence](/artifacts/eu/taxonomy-regulation/minimum-safeguards.md): Understand how Article 18 minimum safeguards fit into EU Taxonomy alignment, which international standards they reference, and what evidence supports the assessment. - [EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx](/artifacts/eu/taxonomy-regulation/faq/non-financial-kpis.md): Article 8 FAQ for non-financial undertakings reporting EU Taxonomy turnover, CapEx and OpEx KPIs, with evidence and source checks. - [EU Taxonomy Penalties and Fines: Article 22 Disclosure Risk](/artifacts/eu/taxonomy-regulation/penalties-and-fines.md): Understand where EU Taxonomy penalty exposure starts: Article 22 measures and penalties for Articles 5, 6, and 7 financial product disclosures, with practical evidence controls. - [EU Taxonomy Regulation Checklist for Eligibility and Alignment](/artifacts/eu/taxonomy-regulation/checklist.md): A cited EU Taxonomy checklist for mapping eligible activities, testing alignment, documenting DNSH and minimum safeguards, and preparing Article 8 KPI disclosures. - [EU Taxonomy Regulation requirements: eligibility, alignment, KPIs](/artifacts/eu/taxonomy-regulation/requirements.md): Understand the core EU Taxonomy requirements: Article 3 alignment tests, eligible activities, DNSH, minimum safeguards, Article 8 KPIs, and evidence to keep. - [EU Taxonomy screening criteria and documentation guide](/artifacts/eu/taxonomy-regulation/screening-criteria-and-documentation.md): How to document EU Taxonomy eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, and Article 8 KPI disclosures without overstating the evidence. - [EU Taxonomy Six Environmental Objectives | Article 9 FAQ](/artifacts/eu/taxonomy-regulation/faq/six-environmental-objectives.md): Plain-English FAQ on the six EU Taxonomy environmental objectives in Article 9 and how teams should map activities, DNSH checks, safeguards, and evidence. - [EU Taxonomy vs CSRD: Article 8 Reporting Comparison](/artifacts/eu/taxonomy-regulation/taxonomy-vs-csrd.md): Compare EU Taxonomy Article 8 disclosures with CSRD sustainability reporting scope, evidence, KPIs, assurance, and reuse limits using official EU Taxonomy sources. - [EU Taxonomy vs SFDR: Scope, KPIs, and Evidence](/artifacts/eu/taxonomy-regulation/taxonomy-vs-sfdr.md): Compare the EU Taxonomy and the SFDR link points that appear in Taxonomy materials: activity classification, Article 8 KPIs, product disclosures, data reuse, and evidence limits. --- [Privacy Policy](https://www.sorena.io/privacy.md) | [Terms of Use](https://www.sorena.io/terms-of-use.md) | [DMCA](https://www.sorena.io/dmca.md) | [About Us](https://www.sorena.io/about-us.md) (c) 2026 Sorena AB (559573-7338). 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