---
title: "EU Taxonomy CapEx Plan Evidence: Article 8 checklist"
canonical_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/capex-plan-evidence"
source_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/capex-plan-evidence"
author: "Sorena AI"
description: "Build evidence for EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2 and the Disclosures Delegated Act."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Taxonomy CapEx plan evidence"
  - "Article 8 CapEx KPI"
  - "Disclosures Delegated Act Annex I"
  - "CapEx plan checklist"
  - "taxonomy-aligned CapEx"
  - "EU Taxonomy reporting"
  - "EU Taxonomy"
  - "Article 8"
  - "CapEx plan"
  - "Disclosures Delegated Act"
  - "CapEx KPI"
  - "taxonomy alignment"
  - "technical screening criteria"
---
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# EU Taxonomy CapEx Plan Evidence: Article 8 checklist

Build evidence for EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2 and the Disclosures Delegated Act.

*Taxonomy* *CapEx evidence* *EU*

## EU Taxonomy Regulation CapEx Plan Evidence

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

Use this page to collect the management approval, activity mapping, timing, expenditure, and contextual disclosures required by the Article 8 framework.

A Taxonomy CapEx plan is not a generic sustainability investment list. Under Annex I to the Disclosures Delegated Act, it is the evidence route for capital expenditure that is part of a plan to expand Taxonomy-aligned activities or make Taxonomy-eligible activities Taxonomy-aligned. The evidence file should show the affected economic activity, the management-body approval, the planned measures, the timing, the expected capital expenditure, and the link to the technical screening criteria. Timings in this page are source-linked; verify current legal source language before implementation decisions.

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

Start with the CapEx KPI 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.
- Keep the activity-level mapping clear enough to avoid counting the same CapEx across several economic activities or environmental objectives.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Annex I Section 1.1.2.2 defines the CapEx KPI numerator and the CapEx plan route for non-financial undertakings.
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - FAQ 26 explains when an expansion uses the CapEx plan route rather than same-period aligned CapEx treatment.
- [Commission Article 8 FAQ on eligible activities and assets](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Commission FAQ confirms that Article 8 reporting covers turnover, CapEx, and OpEx proportions for non-financial undertakings.

## 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 technical screening criteria 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.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Annex I Section 1.1.2.2 sets the five-year condition, management-body approval requirement, update rule, and maximum 10-year justified period.
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - 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.

## Which disclosure evidence should be retained?

Annex I Section 1.2.3.2 requires contextual information about the CapEx KPI, 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.

- CapEx KPI numerator workbook with line-item references to the non-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.
- Technical screening criteria 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.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Annex I Section 1.2.3.2 lists the contextual information and key information required for each CapEx plan.
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - FAQ 27 says CapEx values under Section 1.1.2.2 points (a), (b), and (c) should be presented at activity level.

*Recommended next step*

*Placement: after evidence section*

## Turn CapEx plan rules into an evidence workflow

Use this EU Taxonomy guide to connect CapEx plan approval, activity mapping, KPI calculations, and contextual disclosure evidence before publication.

- [Open Research Copilot](/solutions/research-copilot.md): Answer EU Taxonomy implementation questions with cited source material.
- [Discuss EU Taxonomy implementation](/contact.md): Review CapEx plan scope, source evidence, and next implementation steps with Sorena.

## 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 technical screening criteria 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 CapEx KPI numerator. Updating the plan restarts the plan period.

- Trigger a review when technical screening criteria for the activity change.
- Record whether the plan was updated within the two-year window or whether the CapEx KPI 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 technical screening criteria.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Annex I sets the update-or-restate rule when technical screening criteria change and requires disclosure of material changes to CapEx plan implementation.
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - FAQ 26 confirms that after completion, the expanded activity still needs to meet the relevant technical screening criteria.

## Common evidence mistakes to remove before publication

Most weak CapEx-plan files fail because they mix eligible, aligned, future-alignment, and individual-measure spending without explaining which Section 1.1.2.2 route is being used. That makes the reported CapEx KPI hard to trace from source rule to accounting amount to 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 technical screening criteria.
- 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.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Binding disclosure rules for CapEx KPI methodology, CapEx plan conditions, contextual information, and restatement triggers.
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Commission interpretation explaining timing, precision, activity-level presentation, and multi-period expansion treatment for CapEx plans.
- [Commission Article 8 FAQ on eligible activities and assets](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Article 8 FAQ grounding the broader reporting context for turnover, CapEx, and OpEx ratios.

## Primary sources

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Binding Disclosures Delegated Act source for Article 8 disclosure content, CapEx KPI methodology, CapEx plan conditions, and contextual information.
  - Quote: "part of a plan to expand Taxonomy-aligned economic activities"
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Official Commission Notice interpreting CapEx plan timing, plan precision, activity-level presentation, and multi-period expansion treatment.
  - Quote: "identify all planned measures"
- [Commission Article 8 FAQ on eligible activities and assets](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Commission FAQ grounding the Article 8 reporting context for turnover, CapEx, OpEx, eligibility, and alignment disclosures.
  - Quote: "turnover, capital and operational expenditure"

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