EU TaxonomyFAQ

EU Taxonomy FAQ

Short answers to the questions that usually slow implementation.

Use this page to settle scope, KPI, and evidence questions before they become reporting errors.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Questions
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

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

The questions below focus on the issues that actually affect reporting outcomes: who is in scope, when comparatives start, how enabling activities work, what minimum safeguards require, and what changed in the current simplification package.

Question 1

Eligibility vs alignment

Q: Is Taxonomy-eligible the same thing as Taxonomy-aligned? A: No. Eligibility means the activity is covered by a Taxonomy activity definition. Alignment means the eligible activity also meets the technical screening criteria, DNSH conditions, and minimum safeguards.

Q: Can an activity be eligible but not aligned? A: Yes. That is common, and it must stay out of aligned KPI numerators.

  • Use separate fields for eligible and aligned in every activity register
  • Do not let a positive eligibility result be treated as a proxy for alignment
  • If evidence is incomplete, the safer operational outcome is not aligned until the file is complete
Question 2

Scope and first-time reporting

Q: Who has to disclose under Article 8? A: Undertakings subject to the sustainability-reporting hooks in Articles 19a or 29a of the Accounting Directive, as further specified by the Article 8 delegated act. Current scope timing should therefore be read together with the current CSRD timetable.

Q: Do first-time reporters need N-1 comparatives? A: No. Commission Notice C/2025/1373 says first-time reporters disclose only year N. N-1 comparatives start from the second reporting year.

  • Large non-listed undertakings were described in Commission guidance as first reporting for FY 2025 with publication in 2026, but later timing should also be checked against Directive (EU) 2025/794
  • If you enter scope for the first time, plan the first report as a single-year disclosure rather than a comparative exercise
  • Even out-of-scope undertakings often still need Taxonomy data because banks, investors, or SFDR products request it
Question 3

Article 8 KPIs and GAR

Q: What do non-financial undertakings disclose? A: Turnover, CapEx, and OpEx proportions associated with eligible and aligned activities, plus the contextual information required by the templates.

Q: What do financial undertakings disclose? A: GAR and other sector-specific KPIs under the delegated act, but the completeness of those KPIs depends heavily on counterparty data quality and coverage.

  • Financial teams should keep a counterparty data pack request ready before each reporting cycle
  • The 2026 simplification act delays the fees and commissions and trading-book template start to 2028
  • Until 31 December 2027, some financial undertakings that do not claim Taxonomy-associated activities may use a simplified statement route
Question 4

Materiality, not-assessed activities, and the 2026 simplification

Q: Can we ignore small activities? A: Not automatically. The 2025 Commission Notice said there is no exemption from the obligation to report, but it also clarified that not-material activities lacking data or evidence should be reported as not aligned without further assessment.

Q: What changed in 2026? A: Delegated Regulation (EU) 2026/73 introduced targeted simplification, including certain 10% non-materiality thresholds for some financial KPI assessments and the option to apply the old rules for FY 2025.

  • Do not convert materiality into a silent omission rule unless the legal text expressly allows it
  • Record non-assessed items separately and explain the treatment in methodology notes
  • Keep a year-by-year note on whether you used the pre-2026 or post-2026 rule set for FY 2025
Question 5

DNSH and minimum safeguards

Q: What is the minimum safeguards test in practice? A: It is a due-diligence and remedy test, not a policy-only test. The evidence should show implemented procedures aligned with OECD, UNGP, ILO, and the International Bill of Human Rights baselines.

Q: Can we claim alignment if one DNSH criterion or one safeguards condition is not demonstrated? A: No. A missing or failed condition breaks the alignment claim.

  • Keep activity-level DNSH evidence and enterprise-level safeguards evidence linked to the same reporting perimeter
  • Track remediation and unresolved incidents because open issues can affect whether the alignment claim is supportable
  • Use the 2023 minimum-safeguards notice as the anchor for review criteria
Recommended next step

Use EU Taxonomy FAQ as a cited research workflow

Research Copilot can take EU Taxonomy FAQ from cited answers to recurring questions on this topic 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

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