EU Taxonomy Regulation deadlines and compliance calendar

Start the calendar with the application dates in Article 27 of the Taxonomy Regulation. Articles 4, 5, 6 and 7 and Article 8(1), (2) and (3) apply from 1 January 2022 for the climate change mitigation and climate change adaptation objectives, and from 1 January 2023 for the other four environmental objectives.

That split matters because a reporting calendar should separate climate-only checks from later checks covering sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems.

The Disclosures Delegated Act gives the practical annual-reporting sequence. For non-financial undertakings, the 2022 phase was limited to Taxonomy-eligible and Taxonomy non-eligible proportions in turnover, CapEx and OpEx plus relevant qualitative information; the non-financial KPI disclosures apply from 1 January 2023.

Financial undertakings had a longer eligibility-only phase from 1 January 2022 until 31 December 2023. Their KPI disclosures apply from 1 January 2024, while credit-institution trading-book and certain commission-and-fee KPI sections apply from 1 January 2026.

The calendar should include a formal delegated-act check before source data is frozen. Commission Delegated Regulation (EU) 2023/2485 amended the Climate Delegated Act by adding technical screening criteria for additional climate mitigation and adaptation activities; it applies from 1 January 2024, except specified Appendix C amendments that apply from 1 January 2025.

The same control should check the Disclosures Delegated Act because Delegated Regulation (EU) 2023/2486 amends Delegated Regulation (EU) 2021/2178. If an activity list, KPI template, or annex reference changed, the calendar should trigger a controlled refresh of activity mapping, DNSH evidence, minimum-safeguards evidence, and KPI workbook formulas.

A useful compliance calendar should name the artifact due at each gate. For non-financial undertakings, that usually means the activity eligibility register, alignment assessment, turnover KPI support, CapEx KPI support, OpEx KPI support, qualitative disclosures, and CapEx plan evidence where a CapEx plan is used.

For financial undertakings, the calendar should distinguish GAR and other financial KPI work from the underlying counterparty data collection. The Disclosures Delegated Act requires KPI disclosures to cover the previous annual reporting period, and the first annual reporting period referenced in Article 8 was 2023.