When should teams use the CapEx plan route?
Use the route only when the CapEx KPI numerator is relying on Annex I Section 1.1.2.2 point (b): expenditure that is part of a plan to expand Taxonomy-aligned activities or upgrade Taxonomy-eligible activities so they become Taxonomy-aligned.
Do not use the label for every sustainability budget. Annex I also has separate CapEx numerator routes for assets or processes already associated with Taxonomy-aligned activities and for certain purchases of Taxonomy-aligned output or individual measures. The record should identify which route is being used before the amount is reported.
From 1 January 2026, Regulation (EU) 2026/73 permits a non-financial undertaking to omit eligibility and alignment assessment for activities whose cumulative CapEx is below 10% of the CapEx KPI denominator. The amount remains in the denominator and must be reported separately as non-material. This option does not turn unassessed expenditure into expenditure or Taxonomy-aligned CapEx.
- Confirm the undertaking is reporting Article 8 turnover, CapEx, and operating expenditure (OpEx) KPIs.
- Map the expenditure to a Taxonomy economic activity and environmental objective.
- Classify the amount as already aligned CapEx, expenditure, or purchase of aligned output and individual measures.
- Use the route for multi-period expansion or upgrade cases where the activity is expected to become Taxonomy-aligned.
- Keep eligibility, alignment, do no significant harm (DNSH), minimum safeguards, and CapEx-plan treatment separate in the evidence file.
- If using the 2026 non-materiality option, retain the CapEx denominator, cumulative 10% test, unassessed activity list, and separate non-material amount.
Citations (4)
- Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)
Annex I Section 1.1.2.2 defines the CapEx KPI numerator routes, including CapEx plans.
part of a plan to expand Taxonomy-aligned economic activities
- Commission Notice C/2023/305 on Article 8 disclosures
FAQ 26 explains when expansion CapEx should use the CapEx plan route rather than same-period aligned CapEx treatment.
where the expansion takes place over several financial periods
- Regulation (EU) 2020/852 (Taxonomy Regulation)
Article 8 requires undertakings in scope to disclose how and to what extent their activities are associated with environmentally sustainable economic activities.
how and to what extent
- Commission Delegated Regulation (EU) 2026/73
Binding source for the CapEx-specific 10% non-materiality assessment option and separate reporting of the related capital expenditure.
below 10 % of the denominator of the CapEx KPI