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FAQDelegated actsEU Taxonomy

EU Taxonomy delegated act changes what teams should check before changing disclosures

Review EU Taxonomy delegated-act updates for effects on eligibility, alignment, do no significant harm (DNSH), and Article 8 disclosures.

Use it to separate adopted rules from proposals, confirm application dates, and keep an evidence trail for criteria changes.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections6 primary sources
Overview

EU Taxonomy can change , DNSH criteria, disclosure templates, key performance indicator (KPI) denominators, and assessment options. For each update, identify whether the act is proposed, adopted, published, in force, or applicable, then update only the affected activities, KPIs, evidence files, and public statements.

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5 of 5 questions
Question 1

What should teams do when EU Taxonomy delegated acts change?

Start from the official Commission delegated-acts page and the relevant EUR-Lex act, not from a saved copy of an old checklist. Regulation (EU) 2020/852 gives the Commission power to specify and Article 8 disclosure information through , so a change can affect both activity assessment and reporting presentation.

Classify the update before changing workflows. On 17 March 2026, the Commission listed proposed amending delegated regulations with public feedback open until 14 April. At that point, those proposals were not adopted or in force. Check for a later adopted act before deciding which rules apply to the reporting period.

Commission Delegated Regulation (EU) 2026/73 is a current example: it was published on 8 January 2026, applies from 1 January 2026, and allows the rules applicable on 31 December 2025 to be used for a financial year starting during 2025. It adds KPI-specific non-materiality options, changes financial-KPI scope and templates, and replaces specified generic DNSH criteria.

  • Confirm the source status: proposed, adopted, published in the Official Journal, applicable, corrected, or amended.
  • Map the act to the affected object: Climate Delegated Act criteria, Environmental Delegated Act criteria, Disclosures Delegated Act templates, DNSH criteria, or Article 8 KPIs.
  • Record the application date separately from the adoption or publication date.
  • Update only affected activities and disclosures; keep unchanged activity conclusions intact unless the source change reaches them.
  • Retain the official URL, short quote, affected internal owner, and evidence-change decision.
  • For a 2025 financial year, document whether the undertaking uses the amended rules or the 31 December 2025 version permitted by Regulation (EU) 2026/73.
Question 2

Which delegated-act changes should the review log distinguish?

The Commission delegated-acts page, as updated on 17 March 2026, listed Commission Delegated Regulation (EU) 2026/73, Commission Delegated Regulation (EU) 2024/3215, Delegated Regulations (EU) 2023/2486 and 2023/2485, Delegated Regulation (EU) 2022/1214, and Delegated Regulation (EU) 2021/2178. Use the act identifier to distinguish a new requirement from an amendment or language correction.

For each reporting period, check EUR-Lex for adoption, publication, entry into force, and application dates. The March 2026 feedback items were proposals at that time; that historical status does not establish which rules apply to a later reporting period.

  • 2026/73: published in the Official Journal on 8 January 2026, amending the Disclosures Delegated Act and simplifying certain for DNSH.
  • 2024/3215: published in the Official Journal on 19 December 2024, correcting certain language versions of Delegated Regulation (EU) 2021/2139.
  • 2023/2486: published in the Official Journal on 21 November 2023 as the Environmental Delegated Act, with criteria for water, circular economy, pollution prevention and control, and biodiversity.
  • 2023/2485: published in the Official Journal on 21 November 2023, amending the Climate Delegated Act by adding for certain activities.
  • March 2026 proposals: public feedback was open until 14 April for proposed usability amendments to Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486; a feedback notice alone does not establish adoption.
Question 3

How should teams decide what to re-check?

Do not reopen every Taxonomy conclusion by default. Re-check conclusions where the delegated act changes the applicable activity description, substantial-contribution criteria, DNSH criteria, minimum documentation expectation, Article 8 disclosure template, KPI methodology, or language that your local assessment relied on.

The Taxonomy Regulation says the should be regularly reviewed and, where appropriate, amended in line with scientific and technological developments. Keep that review log in the evidence file so later reviewers can trace each version decision.

  • Eligibility: check whether the activity description, sector boundary, or NACE economic-activity classification mapping changed.
  • Alignment: re-test substantial-contribution and DNSH criteria for affected activities only.
  • Disclosure: check Article 8 templates, KPI presentation, and qualitative disclosure requirements when the Disclosures Delegated Act changes.
  • Evidence: update source citations, screenshots or extracts, reviewer notes, and version dates used in assessment files.
  • Claims: remove or qualify website, sales, investor, or product statements that cite superseded criteria.
Question 4

What evidence should be retained after a delegated-act review?

Keep the review evidence specific enough that a later reviewer can see why a conclusion changed or why no change was needed. The record should distinguish legal source status from internal implementation status.

For proposals and public-feedback items, retain a watch note rather than changing binding controls too early. For published acts, retain the Official Journal publication reference, application date, affected criteria, and the exact assessment files changed.

  • Official source URL and the date the team checked it.
  • Delegated act identifier, affected prior act, and status: proposal, adopted, published, applicable, correction, or amendment.
  • Affected activities, objectives, DNSH checks, disclosures, KPIs, and public claims.
  • Before-and-after conclusion for each affected assessment, including no-change decisions.
  • Owner, approval date, and next review trigger for future or Commission notices.
Recommended next step

Turn EU Taxonomy delegated-act updates into evidence work

This FAQ helps convert delegated-act changes into source checks, affected-activity reviews, owner decisions, and evidence updates before disclosures or claims change.

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Question 5

Questions and answers

What should teams do first when EU Taxonomy change?

Start with the official Commission delegated-acts page and the relevant EUR-Lex text. First confirm whether the update is proposed, adopted, published, applicable, corrected, or amended, then map it to the affected activity criteria, DNSH criteria, disclosure templates, or KPI methodology before changing workflows.

How do teams know whether a proposed change is already binding?

A public-feedback item is a proposal. Check the relevant EUR-Lex act for adoption, Official Journal publication, entry into force, and application dates before treating it as binding. The March 2026 usability proposals were not adopted or in force at the time of that consultation; check for later official acts before using that status for a later reporting period.

What evidence should be kept after a delegated-act review?

Keep the official source URL, the delegated act identifier, the status, the affected activities or disclosures, and the before-and-after conclusion. For published acts, also keep the Official Journal reference, application date, and the exact assessment files changed.

Primary sources

References and citations

Implementing and delegated acts - Taxonomy Regulation
finance.ec.europa.eu4 citations
Referenced sections
  • Commission page for current Taxonomy Regulation delegated acts, latest public-feedback items, publication dates, and source status.
  • Commission page listing current Taxonomy Regulation delegated acts, latest public-feedback items, publication dates, and act status.
  • Source for the current delegated-act list and the 17 March 2026 public-feedback status.
Show 1 more
  • Commission source for distinguishing latest public-feedback items from published Official Journal acts.
"Taxonomy Regulation gives the Commission the power"
More quoted passages
"not yet adopted and not in force"
"Public feedback open"
"Publication in the Official Journal"
Regulation (EU) 2020/852 (Taxonomy Regulation)
eur-lex.europa.eu4 citations
Referenced sections
  • Primary EU Taxonomy Regulation source for delegated powers, Article 8 disclosures, technical screening criteria, and regular review.
  • Primary regulation authorising delegated acts for Article 8 disclosures and technical screening criteria.
  • Binding Taxonomy source for regular review and amendment of technical screening criteria and for Article 8 disclosure obligations.
Show 1 more
  • Binding Taxonomy source for delegated-act entry into force, the Parliament and Council objection period, and Commission review of screening criteria.
"regularly review the technical screening criteria"
More quoted passages
"The power to adopt delegated acts"
"enter into force only if no objection"
Commission Delegated Regulation (EU) 2023/2485
eur-lex.europa.eu2 citations
Referenced sections
  • Source for the 2023 amendment to the Climate Delegated Act technical screening criteria.
  • EUR-Lex source for the 2023 amendment to the Climate Delegated Act.
"amending Delegated Regulation (EU) 2021/2139"
Commission Delegated Regulation (EU) 2024/3215
eur-lex.europa.eu2 citations
Referenced sections
  • Source for corrections to certain language versions of Delegated Regulation (EU) 2021/2139.
  • EUR-Lex source for the 2024 correction to certain language versions of Delegated Regulation (EU) 2021/2139.
"correcting certain language versions"
Commission Delegated Regulation (EU) 2026/73
eur-lex.europa.eu2 citations
Referenced sections
  • Current binding amendment covering Article 8 simplification, KPI materiality, financial-KPI scope and templates, and specified DNSH criteria from 1 January 2026.
  • Binding example of a multi-act amendment, including its 1 January 2026 application date and transition option for financial years starting in 2025.
"simplification of certain technical screening criteria"
More quoted passages
"It shall apply from 1 January 2026"

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