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TaxonomyCapEx evidenceEU

EU Taxonomy Regulation CapEx Plan Evidence

Document when planned capital expenditure can sit in the EU Taxonomy numerator before the expanded or upgraded activity is complete.

This page helps collect the management approval, activity mapping, timing, expenditure, and contextual disclosures required by the Article 8 framework.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections4 primary sources
Overview

A is the evidence route for capital expenditure used to expand Taxonomy-aligned activities or make Taxonomy-eligible activities Taxonomy-aligned. Keep the affected activity, management-body approval, measures, timing, expected expenditure, and technical-screening-criteria link in one controlled file. For reporting under the rules applying from 1 January 2026, record any permitted CapEx assessment omission before applying this checklist.

Section 1

When does a CapEx plan matter for the Article 8 CapEx KPI?

Start with the numerator. Annex I Section 1.1.2.2 allows numerator treatment for capital expenditure related to Taxonomy-aligned assets or processes, for a qualifying CapEx plan, and for certain purchases of Taxonomy-aligned output or individual measures implemented and operational within 18 months.

A CapEx plan is relevant when spending happens before the expansion or upgrade is complete and the undertaking wants to count that spending as Taxonomy-aligned in the period incurred. If the expanded activity becomes operational in the same financial period as all related CapEx is incurred, the Commission Notice explains that a CapEx plan may not be needed for that expansion route.

  • Confirm the undertaking is reporting the Article 8 turnover, CapEx, and OpEx KPIs as a non-financial undertaking.
  • Identify whether the CapEx relates to an already Taxonomy-aligned activity, a CapEx plan, or an individual measure route.
  • Use the CapEx plan route only for expanding Taxonomy-aligned activities or upgrading or commencing Taxonomy-eligible activities so they become Taxonomy-aligned.
  • If the undertaking uses the amended 10% CapEx assessment threshold, retain the threshold calculation and report the omitted CapEx separately as non-material rather than placing it in an eligibility or alignment category.
  • Keep the activity-level mapping clear enough to avoid counting the same CapEx across several economic activities or environmental objectives.
Section 2

What must the CapEx plan itself prove?

The plan must aim to expand Taxonomy-aligned activities or upgrade Taxonomy-eligible activities so they become Taxonomy-aligned within five years. A longer period is possible only when objectively justified by the specific features of the economic activity and upgrade, and the delegated act caps that period at 10 years.

Evidence should therefore be activity-specific. A board slide that says the company is investing in transition will not be enough unless it identifies the economic activities, planned measures, timing, expected capital expenditure, and the that the activity is expected to meet.

  • Record the economic activity and environmental objective for each CapEx plan.
  • Keep the management-body approval or delegated approval record that starts the five-to-ten-year clock.
  • List the planned measures needed for technical-screening-criteria compliance, including expenditures and significant interim milestones.
  • Exclude spend that does not help the activity meet the relevant criteria, such as facility improvements with no environmental-performance bearing.
  • Add an objective justification inside the plan and contextual information when the expected alignment period exceeds five years.
Section 3

Which disclosure evidence should be retained?

Annex I Section 1.2.3.2 requires contextual information about the , including a quantitative breakdown at economic-activity aggregated level and a qualitative explanation of key changes during the reporting period.

For each CapEx plan, retain the five required disclosure fields: environmental objectives pursued, economic activities concerned, research and innovation activities where relevant, the period in which each activity is expected to be expanded or become aligned, and the total capital expense expected during the reporting period and over the plan period.

  • numerator workbook with line-item references to the financial statements.
  • Activity-level schedule showing which CapEx items fall under Section 1.1.2.2 points (a), (b), or (c).
  • CapEx plan register with objectives, activities, R&D or innovation items where relevant, timing, and expected capital expense.
  • evidence for the activity expected to become aligned.
  • Double-counting check across turnover, CapEx, OpEx, economic activities, and environmental objectives.
  • Contextual explanation for material changes, restatements, or changes in calculation approach.
Recommended next step

Turn CapEx plan rules into an evidence workflow

This EU Taxonomy guide helps connect CapEx plan approval, activity mapping, KPI calculations, and contextual disclosure evidence before publication.

Research workflow
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Section 4

What changes during implementation or amended criteria?

The evidence file should not freeze after approval. Non-financial undertakings must disclose material changes in implementation of CapEx plans, the reasons for those changes, the impact on the potential for activities to become Taxonomy-aligned, and any restatement of CapEx or OpEx KPIs for past reporting years covered by the plan.

If relevant are amended before completion, Annex I requires the undertaking either to update the plan within two years so the activities are aligned with the amended criteria at completion, or to restate the numerator. Updating the plan restarts the plan period.

  • Trigger a review when for the activity change.
  • Record whether the plan was updated within the two-year window or whether the numerator was restated.
  • Explain how implementation changes affect expected alignment timing.
  • Keep restated comparative figures where a calculation change or plan change affects prior KPI disclosures.
  • After completion, verify that the expanded or upgraded activity meets the relevant .
Section 5

Common evidence mistakes to remove before publication

Keep eligible, aligned, future-alignment, and individual-measure spending separate, and explain which Section 1.1.2.2 route each amount uses. A reviewer should be able to trace the reported from the source rule to the accounting amount and economic activity.

A defensible file is narrow: it shows the Article 8 reporting scope, the accounting basis for CapEx, the activity-level allocation, the approval date, the plan period, the planned measures, and the contextual disclosure text that will be published.

  • Do not count a broad transition budget as a CapEx plan unless it identifies the Taxonomy activity, measures, expenditure, timing, and milestones.
  • Do not use CapEx-plan treatment for spend that is unrelated to meeting the .
  • Do not describe the plan as already aligned if the evidence only supports eligibility or future expected alignment.
  • Do not omit management-body or delegated approval evidence; the Commission Notice ties the plan clock to that approval.
  • Do not publish activity-level CapEx values without explaining the related points (a), (b), and (c) treatment and avoiding double counting.
Primary sources

References and citations

Commission Delegated Regulation (EU) 2021/2178
eur-lex.europa.eu6 citations
Referenced sections
  • Binding Disclosures Delegated Act source for Article 8 disclosure content, CapEx KPI methodology, CapEx plan conditions, and contextual information.
  • Annex I Section 1.1.2.2 defines the CapEx KPI numerator and the CapEx plan route for non-financial undertakings.
  • Annex I Section 1.1.2.2 sets the five-year condition, management-body approval requirement, update rule, and maximum 10-year justified period.
Show 3 more
  • Annex I Section 1.2.3.2 lists the contextual information and key information required for each CapEx plan.
  • Annex I sets the update-or-restate rule when technical screening criteria change and requires disclosure of material changes to CapEx plan implementation.
  • Binding disclosure rules for CapEx KPI methodology, CapEx plan conditions, contextual information, and restatement triggers.
"part of a plan to expand Taxonomy-aligned economic activities"
More quoted passages
"approved by the management body"
"key information about each of their CapEx plans"
"update the plan within two years"
"previously published KPI related to capital expenditure shall be restated"
Commission Notice C/2023/305 on Article 8 disclosures
eur-lex.europa.eu6 citations
Referenced sections
  • Official Commission Notice interpreting CapEx plan timing, plan precision, activity-level presentation, and multi-period expansion treatment.
  • FAQ 26 explains when an expansion uses the CapEx plan route rather than same-period aligned CapEx treatment.
  • FAQ 24 says the CapEx-plan time period starts from management-body approval or delegated approval; FAQ 26 explains the precision expected in the plan.
Show 3 more
  • FAQ 27 says CapEx values under Section 1.1.2.2 points (a), (b), and (c) should be presented at activity level.
  • FAQ 26 confirms that after completion, the expanded activity still needs to meet the relevant technical screening criteria.
  • Commission interpretation explaining timing, precision, activity-level presentation, and multi-period expansion treatment for CapEx plans.
"identify all planned measures"
More quoted passages
"where the expansion takes place over several financial periods"
"presented at activity-level"
"needs to meet the relevant TSCs"
"expenditures related to those measures and their timing"
Commission Article 8 FAQ on eligible activities and assets
finance.ec.europa.eu3 citations
Referenced sections
  • Commission FAQ sources support the Article 8 reporting context for turnover, CapEx, OpEx, eligibility, and alignment disclosures.
  • Commission FAQ confirms that Article 8 reporting covers turnover, CapEx, and OpEx proportions for non-financial undertakings.
  • Article 8 FAQ sources support the broader reporting context for turnover, CapEx, and OpEx ratios.
"turnover, capital and operational expenditure"
More quoted passages
"definitions of CapEx and OpEx key performance indicators"
Commission Delegated Regulation (EU) 2026/73
eur-lex.europa.eu2 citations
Referenced sections
  • Binding 2026 amendment for the CapEx assessment threshold, separate non-material reporting, and the option to use the rules in force on 31 December 2025 for a financial year starting in 2025.
  • Article 1 adds the option to omit assessment of activities whose cumulative CapEx is below 10% of the CapEx KPI denominator and requires separate reporting as non-material CapEx.

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