TaxonomyChecklistEU

EU Taxonomy Regulation Checklist

Use this checklist to move from activity mapping to a defensible EU Taxonomy eligibility and alignment conclusion.

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

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
10

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 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 Article 3 alignment conditions, 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 minimum safeguards, 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.
  • DNSH: test the activity against each applicable do-no-significant-harm condition for the other environmental objectives.
  • Minimum safeguards: confirm the undertaking has procedures aligned with the OECD Guidelines, UN Guiding Principles, ILO fundamental principles and rights, and the International Bill of Human Rights as referenced by Article 18.
  • 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.

DNSH 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.
Recommended next step

Turn EU Taxonomy checks into an evidence workflow

Use this EU Taxonomy checklist to 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

Minimum safeguards 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.

  • For non-financial undertakings, reconcile each eligible and aligned activity to turnover, CapEx, and OpEx source systems before disclosure.
  • 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.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Primary delegated act source for climate mitigation and adaptation technical screening criteria and related DNSH conditions.
"technical screening criteria"
eur-lex.europa.eu
Referenced sections
  • Primary delegated act source for Article 8 content, presentation, methodology, financial-undertaking KPIs, and GAR reporting.
"green asset ratio (GAR)"
eur-lex.europa.eu
Referenced sections
  • Supports checking additional climate technical screening criteria and amendments to Climate Delegated Act activity coverage.
"additional technical screening criteria"
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"
finance.ec.europa.eu
Referenced sections
  • Supports maintaining delegated-act references because the Commission page lists current and published delegated acts, amendments, and Taxonomy tools.
"actual list of environmentally sustainable activities"
eur-lex.europa.eu
Referenced sections
  • Primary legal source for Article 8 disclosure obligations and non-financial undertaking KPI categories.
"turnover, capital expenditure and operating expenditure"
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