TaxonomyChange trackerEU

EU Taxonomy Delegated Act Change Tracker

A tracker for separating adopted EU Taxonomy from consultations, notices, and draft changes before they reach activity mapping or KPI calculations.

Use it to connect each official source to the affected screening criteria, DNSH files, Article 8 tables, evidence owner, and reporting-cycle status.

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

EU Taxonomy assessments depend on as well as the 2020 framework regulation. Record the official source, legal status, affected delegated-act family, internal artifact to update, and closure evidence so a draft consultation is not treated like an adopted technical-screening change.

Section 1

Baseline acts to keep in the register

Start with the Commission's Taxonomy Regulation implementing-and-delegated-acts page, then link each row to the EUR-Lex act where available. The Commission page is the practical register for publication status, public-feedback items, the Official Journal notices, and links to the EU Taxonomy Navigator.

Keep adopted delegated regulations, draft delegated regulations, , FAQ material, platform reports, and Taxonomy Navigator lookups in separate tracker statuses. Only adopted delegated regulations, once applicable, should change the binding activity criteria or Article 8 disclosure templates used for the reporting period.

  • Delegated Regulation (EU) 2021/2139: Climate Delegated Act for climate change mitigation and climate change adaptation .
  • Delegated Regulation (EU) 2021/2178: Disclosures Delegated Act specifying Article 8 content, presentation, and disclosure methodology.
  • Delegated Regulation (EU) 2022/1214: Complementary Climate Delegated Act for specified gas and nuclear energy activities and related disclosures.
  • Delegated Regulation (EU) 2023/2485: amendment adding further climate change mitigation and adaptation criteria; Delegated Regulation (EU) 2023/2486: Environmental Delegated Act for the other four objectives and related disclosure updates.
  • Commission Delegated Regulation (EU) 2024/3215 and Commission Delegated Regulation (EU) 2026/73: later register items for language-version corrections and simplification changes that should be reviewed before criteria files, DNSH evidence, or Article 8 templates are reused.
Section 2

Status fields that prevent false implementation

The tracker should show whether a change is published in the Official Journal, adopted but not yet applicable, a public-feedback item, a Commission notice, or non-binding background material. For the March 2026 proposals to amend Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486, check the current Commission register and EUR-Lex record before assigning a status. A planned adoption quarter does not establish adoption or applicability; close the watch item only against the published act and its application date.

For each adopted act, record the act number, signing date where the legal act provides it, Official Journal publication date from the Commission register or EUR-Lex, entry into force, application date, any reporting-year option or transition, affected delegated regulation, and a short implementation note written in business terms rather than only legal shorthand. "Adopted" and "applicable" are separate statuses.

  • Binding source status: adopted delegated regulation, Official Journal publication, application date if the source states one, and whether the act amends 2021/2139, 2021/2178, 2023/2486, or another act.
  • Watch status: public-feedback items, draft notices, draft delegated regulations, platform reports, or Commission FAQ material that may guide interpretation but should not alter final KPI calculations on its own.
  • Correction status: language-version corrections, such as 2024/3215, routed first to legal and local-language owners before changing English evidence files.
  • Simplification status: Regulation (EU) 2026/73 applies from 1 January 2026 and changes Article 8 materiality, templates, financial-undertaking calculation rules and application dates, while replacing specified chemicals DNSH criteria in 2021/2139 and 2023/2486.
  • Closure status: not assessed, no impact with a reason, in progress with an owner and due date, closed with updated artifact and reviewer links, or deferred because the source does not yet support implementation.
Section 3

Impact tags for activity, DNSH, and disclosure work

Classify every change by the assessment step it can alter. A changed activity description affects eligibility mapping first; changed substantial-contribution or DNSH criteria affect alignment evidence; changed Article 8 content or presentation affects disclosure templates, KPI notes, and assurance tie-outs.

Use and FAQ material as interpretation support, not as delegated-act amendments. Notices are still useful references for reviewer questions, especially when a criteria file, DNSH checklist, or KPI workbook needs to explain why a source was applied in a particular way.

  • Eligibility impact: the act adds or changes an economic activity covered by the Taxonomy criteria, so the activity register and NACE/activity mapping need review.
  • Alignment impact: the act changes substantial-contribution criteria, DNSH criteria, Appendix C references, measurement conditions, exclusions, or evidence expectations for an activity already mapped.
  • Article 8 impact: the act changes disclosure content, presentation, templates, KPI methodology, GAR-related tables, or qualitative explanations.
  • Objective impact: tag climate change mitigation, climate change adaptation, water and marine resources, circular economy, pollution prevention and control, biodiversity and ecosystems, or disclosure-only.
  • Interpretation impact: notices, FAQs, and navigator entries help resolve application questions but should not be logged as binding amendments to the criteria text.
  • Transition impact: record whether a financial-year transition, delayed KPI start, temporary opt-out, or grandfathering rule applies to a particular exposure rather than to the activity criteria generally.
Section 4

Records to close before reporting

Before a Taxonomy reporting cycle closes, every adopted delegated-act change in scope should have a closed tracker row or a narrow out-of-scope rationale. The row should show exactly why an act affected, or did not affect, an activity register, DNSH file, KPI workbook, GAR workbook, or published Article 8 narrative.

A strong tracker gives assurance reviewers a path from legal source to non-public evidence. It shows which source text changed, which internal artifact was touched, who approved the update, and whether prior-period reporting needs a note or reconciliation.

  • Source record: Commission register link, EUR-Lex link where available, act number, act title, status, publication date, and affected delegated act.
  • Assessment record: impacted objective, affected activity or disclosure table, old criterion reference, new criterion reference, and whether the change affects eligibility, alignment, DNSH, or Article 8 presentation.
  • Evidence record: updated activity mapping, screening-criteria extract, DNSH evidence, CapEx plan support, turnover/CapEx/OpEx workbook, GAR workbook, or disclosure narrative.
  • Review record: owner, legal reviewer, sustainability reviewer, finance reviewer if KPIs are affected, due date before the affected reporting close, approval date, unresolved interpretation questions, and source version reviewed.
  • Publication record: final disclosure wording checked against the source status, with voluntary information and draft-watch items kept separate from mandatory reporting.
Recommended next step

Turn delegated-act changes into reportable evidence

This tracker helps connect each EU Taxonomy delegated-act change to activity mapping, DNSH evidence, KPI workbooks, owners, and disclosure updates before the reporting cycle closes.

Primary sources

References and citations

finance.ec.europa.eu3 citations
Referenced sections
  • Primary Commission register for the listed delegated acts, public-feedback items, Official Journal publication entries, and links to Taxonomy tools.
  • Lists the Taxonomy delegated-act register, including 2026/73, 2024/3215, 2023/2486, 2023/2485, 2022/1214, 2021/2178, Climate Delegated Act material, and current public-feedback items.
  • Supports the register fields for latest public-feedback status, Official Journal publication entries, and the listed simplification, correction, environmental, complementary climate, disclosure, and climate delegated acts.
"implementing and delegated acts"
More quoted passages
"Publication in the Official Journal"
eur-lex.europa.eu2 citations
Referenced sections
  • Article 8 delegated act for disclosure content, presentation, methodology, and financial and non-financial undertaking KPI reporting.
  • Supports tracking Article 8 content, presentation, methodology, and KPI disclosure changes separately from activity-screening criteria.
"content and presentation"
eur-lex.europa.eu2 citations
Referenced sections
  • Language-version correction act for Delegated Regulation (EU) 2021/2139; useful for routing correction items separately from substantive English criteria changes.
  • Grounds the correction category: this act corrects certain language versions of Delegated Regulation (EU) 2021/2139 and does not concern the English language version.
"correcting certain language versions"
eur-lex.europa.eu2 citations
Referenced sections
  • Binding amendment applying from 1 January 2026; central source for the current Article 8, transition, and specified chemicals DNSH changes that a tracker must route.
  • Binding source for current Article 8 and Appendix C changes, the 2025 financial-year transition, the financial-undertaking opt-out through 31 December 2027, and the limited five-year treatment for certain known-use-of-proceeds loans and instruments after criteria amendments.
eur-lex.europa.eu2 citations
Referenced sections
  • Interpretation source for Climate Delegated Act technical screening criteria and DNSH questions.
  • Supports using Commission notices as interpretation material for Climate Delegated Act technical screening criteria and DNSH questions.
"technical screening criteria"
eur-lex.europa.eu2 citations
Referenced sections
  • Interpretation source for Article 8 reporting questions involving Taxonomy-eligible and Taxonomy-aligned activities.
  • Supports using notices to document Article 8 reporting interpretations for Taxonomy-eligible and Taxonomy-aligned activities.
"Taxonomy-aligned economic activities"
eur-lex.europa.eu2 citations
Referenced sections
  • Binding framework for the Taxonomy system, including the environmental objectives, DNSH, minimum safeguards, technical screening criteria, and Article 8 disclosure basis.
  • Establishes the framework that delegated acts supplement through technical screening criteria, DNSH, minimum safeguards, and Article 8 disclosure obligations.
"framework to facilitate sustainable investment"
eur-lex.europa.eu
Referenced sections
  • EUR-Lex draft for the Environmental Delegated Act revision. It is a proposal and must not be used as binding criteria before adoption, Official Journal publication, and application.
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