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EU Taxonomy Regulation What is in scope for Article 8 disclosures

A practical answer for teams deciding whether Article 8 applies and which Taxonomy disclosure framework to use.

Use this FAQ to separate legal reporting scope from activity eligibility, KPI methodology, and supporting evidence.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Article 8 scope is about who must include EU Taxonomy information in the non-financial statement or consolidated non-financial statement. The starting point is not whether one activity looks green; it is whether the undertaking is subject to Articles 19a or 29a of Directive 2013/34/EU and then whether it reports as a non-financial undertaking or a financial undertaking under the Disclosures Delegated Act.

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4 of 4 questions
Question 1

What is the Article 8 scope test?

Article 8 of Regulation (EU) 2020/852 applies to undertakings that are subject to the obligation to publish non-financial information under Article 19a or Article 29a of Directive 2013/34/EU. Those undertakings must include information on how and to what extent their activities are associated with economic activities that qualify as environmentally sustainable.

The practical scope decision should therefore begin with the reporting entity and consolidation boundary. If the undertaking is in scope, the next question is which disclosure route applies: non-financial undertaking KPIs under Annexes I and II of Commission Delegated Regulation (EU) 2021/2178, or the financial undertaking rules for asset managers, credit institutions, investment firms, and insurance or reinsurance undertakings.

  • Confirm whether the entity or group prepares non-financial information under Article 19a or consolidated non-financial information under Article 29a.
  • Classify the reporter as a non-financial undertaking or as the relevant type of financial undertaking before selecting KPI templates.
  • Document the reporting boundary separately from the later assessment of Taxonomy eligibility or Taxonomy alignment.
Citations
Question 2

Which KPI framework applies once an undertaking is in scope?

For non-financial undertakings, Article 8(2) points to the proportion of turnover, capital expenditure, and operating expenditure related to assets or processes associated with environmentally sustainable economic activities. The Disclosures Delegated Act then requires those disclosures as specified in Annex I and presented using the templates in Annex II.

For financial undertakings, turnover, CapEx, and OpEx do not describe lending, investment, insurance, or similar financial activities in the same way. Commission Delegated Regulation (EU) 2021/2178 therefore provides separate KPI methodologies for asset managers, credit institutions, investment firms, and insurance or reinsurance undertakings.

  • Use turnover, CapEx, and OpEx KPIs for non-financial undertakings.
  • Use the relevant financial undertaking annexes for asset managers, credit institutions, investment firms, insurers, and reinsurers.
  • Do not treat activity eligibility as proof of alignment; eligibility means the activity is described in Taxonomy delegated acts, while alignment requires the Article 3 conditions.
Citations
Question 3

Where should Article 8 information appear?

The Disclosures Delegated Act requires additional disclosures accompanying the KPIs to appear in the same part of the non-financial statement as the indicators, or to be cross-referenced from that part. The same Article 8 provisions also require KPIs to cover the previous annual reporting period and to use the same currency as the financial statements.

That makes the evidence file more than a legal memo. It should tie the in-scope entity, financial statement currency, previous reporting period, chosen KPI route, and cross-references to the non-financial statement into one reviewable record.

  • Record where the Article 8 disclosures appear in the non-financial statement or consolidated non-financial statement.
  • Keep the previous annual reporting period and reporting currency consistent with the Article 8 disclosure basis.
  • Preserve cross-references to KPI tables, qualitative information, and any voluntary information that is kept separate from mandatory disclosures.
Citations
Question 4

What evidence should teams keep for the Article 8 scope decision?

Keep evidence that explains why the entity is in scope, which undertaking type was used for the KPI framework, and how the disclosure record connects to the annual reporting package. A useful record should be readable by sustainability, finance, legal, and audit reviewers without relying on undocumented assumptions.

For financial undertakings, the record should also capture scope exclusions and numerator limits where relevant, such as the common Article 7 treatment for exposures to central governments, central banks, supranational issuers, derivatives, and undertakings not obliged to publish non-financial information.

  • Entity or group scope memo referencing Article 19a or Article 29a where applicable.
  • Undertaking classification memo: non-financial undertaking or specific financial undertaking type.
  • KPI route selection with annex references and template owner.
  • Disclosure placement record showing the non-financial statement section or cross-reference.
  • Evidence log for assumptions, voluntary disclosures, exclusions, and unresolved scope questions.
Citations
Recommended next step

Turn EU Taxonomy scope decisions into evidence

Use this EU Taxonomy guide to connect Article 8 scope, KPI route selection, source citations, owners, and disclosure evidence before teams publish or review reporting.

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Primary sources

References and citations

Commission Delegated Regulation (EU) 2021/2178
eur-lex.europa.eu
Referenced sections
  • Source for undertaking categories, Article 7 exclusions, and common Article 8 disclosure rules.
"Disclosure rules common to all financial undertakings"
European Commission Article 8 Disclosures FAQ
finance.ec.europa.eu
Referenced sections
  • Commission FAQ supporting practical evidence points for scope, timing, and voluntary disclosures.
"voluntary disclosures are not part of the mandatory disclosures"
Regulation (EU) 2020/852 (Taxonomy Regulation)
eur-lex.europa.eu
Referenced sections
  • Primary source for the Article 8 obligation and its link to Articles 19a and 29a of Directive 2013/34/EU.
"subject to an obligation to publish non-financial information"
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