TaxonomyChecklistEU

EU Taxonomy Regulation Checklist

This checklist helps move from activity mapping to a defensible EU Taxonomy eligibility and alignment conclusion.

The checks cover eligible activities, substantial contribution, , , Article 8 KPIs, and evidence records.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

EU Taxonomy work should not start with a green claim. Start with the economic activity, identify the applicable delegated-act criteria, test the , and keep the evidence needed for Article 8 reporting and review.

Section 1

1. Map the economic activity before making a Taxonomy claim

Record the legal entity, reporting boundary, business line, product or service, revenue stream, CapEx project, or OpEx category being assessed. The Taxonomy is an activity classification system, so a broad company-level sustainability statement is not enough.

Use the Commission Taxonomy hub, the EU Taxonomy Navigator or Compass, and the relevant delegated acts to identify whether the activity is covered. If the activity is not covered by technical screening criteria, do not describe it as Taxonomy-aligned; keep the conclusion limited to the eligibility assessment.

  • Name the economic activity and match it to the relevant delegated act, sector, activity description, and NACE reference where the source uses one.
  • Separate Taxonomy-eligible, Taxonomy-aligned, and not-covered activities in the working file.
  • Record which environmental objective is being tested: climate mitigation, climate adaptation, water and marine resources, circular economy, pollution prevention and control, or biodiversity and ecosystems.
  • Check whether the activity is covered by the Climate Delegated Act, Complementary Climate Delegated Act, Environmental Delegated Act, or later delegated-act amendments before finalizing the assessment.
  • Keep a dated source link for the delegated act or Commission tool used, because technical screening criteria and disclosure rules can be amended.
Section 2

2. Test Article 3 alignment conditions in order

A covered activity is not automatically Taxonomy-aligned. The Regulation requires the activity to contribute substantially to one or more environmental objectives, do no significant harm to the other objectives, comply with , and meet the applicable technical screening criteria.

Keep the four-part conclusion visible for every assessed activity. A single missing part should stop an alignment claim, even when the activity is eligible or strategically important.

  • Substantial contribution: cite the exact objective and technical screening criterion that the activity satisfies.
  • : test the activity against each applicable do-no-significant-harm condition for the other environmental objectives.
  • : confirm the undertaking has procedures aligned with the OECD Guidelines and UN Guiding Principles, including the principles and rights in the eight ILO fundamental conventions referenced by Article 18 and the International Bill of Human Rights.
  • Technical screening criteria: keep the delegated-act section, version, calculation, certificate, engineering evidence, or other proof used for the conclusion.
  • Conclusion wording: say Taxonomy-aligned only when all Article 3 conditions are evidenced; otherwise use narrower wording such as eligible, not covered, or not aligned.
Section 3

3. Build an evidence file for technical screening and DNSH

The checklist should produce a reviewable evidence file, not just a yes-or-no table. For each activity, attach the source criterion, the measured or documented fact, the calculation owner, and the reviewer who accepted the evidence.

evidence should be objective-specific. Do not reuse a climate-mitigation calculation as proof that water, circular economy, pollution, or biodiversity conditions have also been met unless the relevant delegated-act criterion actually allows that evidence.

  • For every criterion, store the source URL, delegated-act reference, activity description, environmental objective, evidence owner, evidence date, and reviewer.
  • Keep calculation workpapers for emissions, energy, turnover, CapEx, OpEx, or activity-specific thresholds only where the relevant source requires those measures.
  • Attach permits, design specifications, lifecycle evidence, supplier declarations, assurance workpapers, or management approvals only when they support a specific criterion.
  • Flag estimates, data gaps, unsupported supplier claims, and assumptions separately from confirmed evidence.
  • When a delegated act has been amended, record whether the old or amended criterion applies to the reporting period and why.
  • For Appendix C chemicals checks from 1 January 2026, use the replacement text in Regulation (EU) 2026/73. Do not reuse the removed broad CLP hazard-class screen from the earlier version.
Recommended next step

Turn EU Taxonomy checks into an evidence workflow

This EU Taxonomy checklist helps connect activity mapping, technical screening criteria, DNSH evidence, minimum safeguards, and Article 8 KPI workpapers before reporting or publication.

Section 4

4. Document minimum safeguards before signing off alignment

are not a branding statement. Article 18 refers to procedures implemented by the undertaking to align with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, including ILO fundamental principles and the International Bill of Human Rights.

For checklist purposes, require evidence of the procedure, owner, scope, escalation route, and any material unresolved findings. The Platform on Sustainable Finance report is advisory rather than binding, but it is useful implementation context for human rights due diligence, bribery, taxation, and fair competition topics.

  • Identify the undertaking whose safeguards are being assessed and whether the evidence covers the activity, entity, and value-chain risk profile.
  • Keep human rights due diligence policies, risk assessments, grievance channels, remediation records, and board or management oversight evidence where applicable.
  • Check whether unresolved court findings, OECD National Contact Point cases, corruption, tax, or competition issues affect the safeguards conclusion.
  • Do not treat supplier codes, ESG ratings, or public commitments as sufficient by themselves unless the underlying procedure and follow-up evidence are available.
  • Record whether the safeguards conclusion is complete, incomplete, or blocked by unresolved findings before using Taxonomy-aligned language.
Section 5

5. Reconcile Article 8 disclosures and KPI evidence

Article 8 reporting should reconcile the activity assessment with finance systems. For non-financial undertakings, the Regulation identifies turnover, capital expenditure, and operating expenditure proportions associated with environmentally sustainable activities; the Disclosures Delegated Act specifies content, presentation, and methodology.

Financial undertakings need their own KPI logic. The Disclosures Delegated Act identifies the green asset ratio as the main KPI for credit institutions and sets separate disclosure approaches for asset managers, investment firms, and insurance or reinsurance undertakings. Regulation (EU) 2026/73 changed the templates, denominator rules, materiality options, and some application dates.

  • For non-financial undertakings, reconcile each eligible and aligned activity to turnover, CapEx, and OpEx source systems before disclosure.
  • For non-financial undertakings using a 10% non-materiality option, keep the omitted assessment population in the denominator and report it separately as non-material; if all OpEx is treated as immaterial to the business model, disclose the denominator and explain why.
  • For credit institutions, check GAR inputs, excluded exposures, green bonds or debt securities for specific identified activities, and qualitative explanations.
  • For asset managers, investment firms, insurers, and reinsurers, use the relevant Disclosures Delegated Act annexes instead of copying non-financial undertaking KPIs.
  • Keep the reporting period, currency, denominator, numerator, cross-reference, and qualitative explanation with each KPI.
  • Do not mix eligible and aligned figures in labels, charts, or marketing copy; keep both the percentage and the basis of calculation clear.
  • If a financial undertaking uses the conditional opt-out through 31 December 2027, verify the required management-report statement and that no Taxonomy-association claim is made.
Primary sources

References and citations

eur-lex.europa.eu5 citations
Referenced sections
  • Primary legal source for the EU Taxonomy framework, Article 3 alignment conditions, Article 8 disclosures, Article 9 environmental objectives, Article 17 DNSH, and Article 18 minimum safeguards.
  • Primary legal source for the six environmental objectives and the framework for environmentally sustainable economic activities.
  • Primary legal source for Article 3 conditions, environmental objectives, DNSH, minimum safeguards, and delegated technical screening criteria.
Show 2 more
  • Primary legal source for Article 18 minimum safeguards and the referenced OECD, UN, ILO, and human-rights frameworks.
  • Primary legal source for Article 8 disclosure obligations and non-financial undertaking KPI categories.
"qualify as environmentally sustainable"
More quoted passages
"six environmental objectives"
"procedures implemented by an undertaking"
"turnover, capital expenditure and operating expenditure"
eur-lex.europa.eu3 citations
Referenced sections
  • Current binding amendment for Article 8 materiality and templates, financial-undertaking calculations and temporary opt-out, later KPI application dates, and specified chemicals DNSH criteria.
  • Binding amendment replacing specified Appendix C chemicals DNSH criteria and applying from 1 January 2026.
  • Binding source for revised Article 8 templates, 10% non-materiality options, denominator rules, the financial-undertaking opt-out through 31 December 2027, and the 2028 deferral of specified credit-institution KPIs.
finance.ec.europa.eu3 citations
Referenced sections
  • Commission page for checking current delegated and implementing acts, amendments, technical screening criteria, and Taxonomy tools.
  • Supports checking the current delegated acts that define technical screening criteria and reporting obligations.
  • Supports maintaining delegated-act references because the Commission page lists current and published delegated acts, amendments, and Taxonomy tools.
"technical screening criteria for each environmental objective"
More quoted passages
"actual list of environmentally sustainable activities"
eur-lex.europa.eu2 citations
Referenced sections
  • Primary delegated act source for climate mitigation and climate adaptation technical screening criteria and DNSH conditions.
  • Primary delegated act source for climate mitigation and adaptation technical screening criteria and related DNSH conditions.
"technical screening criteria"
eur-lex.europa.eu2 citations
Referenced sections
  • Primary delegated act source for Article 8 disclosure content, presentation, methodology, financial-undertaking KPIs, and GAR reporting.
  • Primary delegated act source for Article 8 content, presentation, methodology, financial-undertaking KPIs, and GAR reporting.
"green asset ratio (GAR)"
eur-lex.europa.eu2 citations
Referenced sections
  • Delegated act source for additional climate technical screening criteria and amendments to the Climate Delegated Act.
  • Supports checking additional climate technical screening criteria and amendments to Climate Delegated Act activity coverage.
"additional technical screening criteria"
eur-lex.europa.eu2 citations
Referenced sections
  • Commission interpretive notice supporting practical questions on technical screening criteria and DNSH under the Climate Delegated Act.
  • Commission interpretation of technical screening criteria and DNSH questions under the Climate Delegated Act.
"interpretation and implementation guidance"
finance.ec.europa.eu2 citations
Referenced sections
  • Commission overview supporting the page's explanation of the Taxonomy as an activity classification system and market transparency tool.
  • Supports the activity-mapping approach and the use of Commission Taxonomy tools and delegated acts to find covered activities and criteria.
"classification system that defines criteria"
finance.ec.europa.eu2 citations
Referenced sections
  • Advisory Platform report used as implementation context for Article 18 minimum safeguards, including human rights due diligence, bribery, taxation, and fair competition.
  • Advisory Platform report supporting practical minimum-safeguards review topics, including human rights due diligence, bribery, taxation, and fair competition.
"Human Rights Due Diligence at the core"
eur-lex.europa.eu
Referenced sections
  • Commission interpretive notice supporting Article 8 reporting checks for Taxonomy-eligible and Taxonomy-aligned economic activities and assets.
"Taxonomy-eligible and Taxonomy-aligned"
Show all related guides (37)

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.

EU Taxonomy compliance guide: eligibility, alignment and Article 8 KPIs

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

EU Taxonomy calendar covering Article 8 reporting phases, 2026 disclosure changes, environmental objective dates, and evidence review gates.

EU Taxonomy Delegated Act Change Tracker

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 Acts Tracker

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

EU Taxonomy DNSH and minimum safeguards guide covering Article 3 alignment, Article 17 harm tests, Article 18 procedures, evidence, and KPI controls.

EU Taxonomy DNSH Appendix C: chemicals evidence guide

Current EU Taxonomy Appendix C chemicals guide covering the 2026 replacement criteria, listed substances, legal exemptions, the candidate-list substance threshold, and evidence records.

EU Taxonomy Eligibility vs Alignment

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

Explain EU Taxonomy eligibility and alignment under Article 8, the Disclosures Delegated Act, Article 3, technical screening criteria, DNSH, and safeguards.

EU Taxonomy FAQ: eligibility, alignment, DNSH, safeguards, and Article 8

EU Taxonomy FAQ hub for eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, Article 8 KPIs, delegated acts, and evidence records.

EU Taxonomy GAR and financial undertaking KPIs

EU Taxonomy Article 8 financial undertaking KPI guide covering GAR, sector KPIs, 2026 denominator rules, materiality options, exclusions, and evidence.

EU Taxonomy GAR KPI workflow for credit institutions

Prepare EU Taxonomy Green Asset Ratio stock and flow disclosures with current rules for covered assets, exclusions, materiality, and evidence.

EU Taxonomy Minimum Safeguards: Article 18 and evidence

Understand how Article 18 minimum safeguards fit into EU Taxonomy alignment, which international standards they reference, and what evidence supports the assessment.

EU Taxonomy Penalties and Fines: Article 22 Disclosure Risk

EU Taxonomy Article 22 explains who sets penalties for Articles 5, 6, and 7 financial product disclosures and how to research the applicable national rule.

EU Taxonomy Regulation requirements: eligibility, alignment, KPIs

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

How to document EU Taxonomy eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, and Article 8 KPI disclosures without overstating the evidence.

EU Taxonomy vs CSRD: Article 8 Reporting Comparison

Compare EU Taxonomy Article 8 disclosures with current Accounting Directive sustainability-reporting scope, evidence, KPIs, assurance, and reuse limits.

EU Taxonomy vs SFDR: Scope, KPIs, and Evidence

Compare EU Taxonomy activity tests and Article 8 KPIs with SFDR entity and product disclosures, evidence, publication channels, and limits on data reuse.

DNSH Appendix C under the EU Taxonomy: chemicals evidence FAQ

Practical FAQ on the current EU Taxonomy DNSH Appendix C chemicals criteria, including listed substances, the 0.1% w/w SVHC threshold, alternatives, and controlled conditions.

EU Taxonomy 2026 simplification: what should teams do?

cited FAQ on EU Taxonomy 2026 simplification, Regulation (EU) 2026/73, Article 8 reporting, DNSH evidence, and limits on unsupported claims.

EU Taxonomy activity evidence packs: what to retain

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 Scope FAQ

Practical 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

Practical FAQ on EU Taxonomy auditor evidence: what evidence supports eligibility, alignment, DNSH, minimum safeguards, and Article 8 KPI disclosures.

EU Taxonomy CapEx Plans FAQ: Article 8 CapEx KPI

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 delegated act changes: what teams should check

FAQ on handling EU Taxonomy delegated act changes: official source checks, application dates, affected criteria, disclosures, DNSH evidence, and review records.

EU Taxonomy eligibility vs alignment: what is the difference?

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 Financial KPIs and Green Asset Ratio (GAR) FAQ

FAQ on EU Taxonomy Article 8 financial undertaking KPIs, credit institution Green Asset Ratio (GAR), reporting dates, exclusions, and qualitative disclosures.

EU Taxonomy gas and nuclear activities: when can they align?

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

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 non-financial KPIs: turnover, CapEx and OpEx

Article 8 FAQ for non-financial undertakings reporting EU Taxonomy turnover, CapEx and OpEx KPIs, with evidence and source checks.

EU Taxonomy Six Environmental Objectives | Article 9 FAQ

Plain-English FAQ on the six EU Taxonomy environmental objectives in Article 9 and how teams should map activities, DNSH checks, safeguards, and evidence.