EU TaxonomyTracker

EU Taxonomy Delegated acts tracker

The framework is stable. The operational detail moves through delegated acts and notices.

Track both criteria changes and disclosure changes so activity decisions stay reproducible.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
7

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

Taxonomy projects break when teams mix the framework regulation with the delegated acts that actually define the criteria and templates. A usable tracker separates the framework layer, the technical-screening layer, the disclosure layer, and the interpretation layer. That is what lets you defend which version you used for a given reporting year.

Section 2

What each act changes in practice

Your tracker should answer four operational questions: does the act add activities, change thresholds, change DNSH work, or change disclosure templates. If the answer is yes, the impacted pages in your internal workbook and evidence vault should be listed immediately.

This is especially important after the 2026 simplification act because it affects both what must be assessed and how it may be presented.

  • 2021/2139: determines whether a climate-related activity is eligible and what substantial contribution and DNSH tests apply
  • 2021/2178: determines how turnover, CapEx, OpEx, GAR, GIR, and other Article 8 outputs are calculated and shown
  • 2022/1214: changes climate activity coverage for certain gas and nuclear activities and adds related disclosure points
  • 2023/2486: brings the four non-climate objectives into the screening and disclosure system
  • 2026/73: adds simplification, non-materiality thresholds in certain cases, optional FY 2025 use of the pre-2026 rules, and pushes some financial templates to 2028
Section 3

Interpretation notices belong in the same tracker

EUR-Lex notices are not optional reading. They answer the implementation questions that repeatedly cause restatements, such as first-year comparatives, enabling-activity allocation, and how to treat not-material activities when evidence is missing.

Treat each notice as a methodology source. Record which FAQs your team relied on and where the answer affects a workbook formula, narrative note, or evidence standard.

  • 2022/C 385/01: first notice focused on eligibility disclosures
  • C/2023/305: second notice focused on non-financial reporting of eligible and aligned activities
  • 2023/C 211/01: minimum safeguards notice explains Article 18 expectations and the link to OECD, UNGP, ILO, and SFDR social PAIs
  • C/2025/1373: current broad implementation notice covering climate, environmental, and disclosure questions
Section 4

Tracker fields that actually help

Do not build a decorative tracker. Build one that triggers a task, identifies an owner, and points to the exact activity, note, or workbook tab that changes.

A good tracker also separates the legal effective date from the first reporting year in which the change matters.

  • Act or notice ID and full title
  • Type: framework, criteria, disclosure, or interpretation
  • Publication date, entry into force, and application date
  • Affected activities, entities, and KPIs
  • Evidence impact: new criterion, removed criterion, or revised DNSH work
  • Disclosure impact: template, formula, contextual note, or comparative requirement
  • Internal actions, owner, due date, and methodology note reference
Recommended next step

Operationalize EU Taxonomy Delegated acts tracker across ESG workflows

ESG Compliance can take EU Taxonomy Delegated acts tracker from operationalizing this sustainability obligation across workflows and reporting to a reusable workflow inside Sorena. Teams working on EU Taxonomy can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Primary sources

References and citations

Related guides

Explore more topics

EU Taxonomy Applicability Test (Article 8): In-Scope Entities, Activities, and Disclosures
A practical EU Taxonomy applicability test for Regulation (EU) 2020/852 and Article 8 disclosures: determine whether your entity must disclose.
EU Taxonomy Checklist (Article 8): Audit-Ready Eligibility, Alignment, KPIs, Evidence Packs
An audit-ready EU Taxonomy checklist for Regulation (EU) 2020/852 and Article 8 disclosures: scope/perimeter, activity mapping.
EU Taxonomy Compliance Program (Article 8): Implementation Playbook for KPIs and Evidence
A practical EU Taxonomy compliance program playbook for Regulation (EU) 2020/852: set governance, build an activity mapping register.
EU Taxonomy Deadlines and Disclosure Calendar: Article 8 Reporting Dates, 2026 Simplification, GAR
A practical EU Taxonomy calendar covering Regulation (EU) 2020/852, the Article 8 disclosure timetable, the 2023 and 2024 reporting phases.
EU Taxonomy DNSH and Minimum Safeguards: Evidence, OECD, UNGP, ILO, SFDR Link
A practical guide to EU Taxonomy DNSH and minimum safeguards.
EU Taxonomy Enforcement, Measures, Penalties and Fines (Articles 5-7)
How EU Taxonomy enforcement works in practice: competent authorities monitor compliance for disclosures under Articles 5 to 7.
EU Taxonomy FAQ: Article 8, Eligibility vs Alignment, GAR, Minimum Safeguards, 2026 Simplification
A grounded EU Taxonomy FAQ covering Article 8 scope, eligibility vs alignment, turnover CapEx OpEx KPIs, GAR, minimum safeguards, the 2025 Commission Notice.
EU Taxonomy KPIs and Disclosure Workflow: Turnover, CapEx, OpEx, GAR, Article 8
Build an EU Taxonomy disclosure workflow that can survive review.
EU Taxonomy Requirements (2020/852): Eligibility, Alignment, DNSH, Minimum Safeguards, Article 8 KPIs
A practical requirements breakdown for Regulation (EU) 2020/852 (EU Taxonomy): what environmentally sustainable means.
EU Taxonomy Scope and Reporting Entities: Who Must Disclose Under Article 8
Understand EU Taxonomy scope and reporting entities under Article 8.
EU Taxonomy Technical Screening Criteria: Documentation, Evidence Packs, and Audit Trail
How to document EU Taxonomy alignment against technical screening criteria: build a criteria-by-criteria mapping.
EU Taxonomy Templates (Activity Register, KPI Workbook, Evidence Pack Index, DNSH, Safeguards)
Practical EU Taxonomy templates you can copy/paste: activity mapping register, eligibility/alignment register, criteria mapping template, DNSH register.
EU Taxonomy vs CSRD: How Article 8 Taxonomy Disclosures Fit Into CSRD Reporting
Compare EU Taxonomy and CSRD the practical way. Learn how Article 8 Taxonomy disclosures fit inside the broader CSRD reporting system.
EU Taxonomy vs SFDR: How Taxonomy Data Flows Into GAR, Product Disclosures, and Investor Requests
Understand the practical relationship between EU Taxonomy and SFDR.
Taxonomy Eligibility vs Alignment (EU Taxonomy): What You Can Claim, What You Must Prove
A high-signal explainer of EU Taxonomy eligibility vs alignment: eligibility means the activity is covered/listed.