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FAQDelegated actsEU Taxonomy

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

A cited FAQ for turning EU Taxonomy delegated-act updates into practical review steps for eligibility, alignment, 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
Jul 24, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

EU Taxonomy can change , DNSH criteria, disclosure templates, 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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4 of 4 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. The Commission page captured in the cited source material lists adopted and published acts, but it also listed proposed amending delegated regulations on 17 March 2026 that were open for public feedback until 14 April and were not yet adopted or in force until publication in the Official Journal.

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.
Citations
Question 2

Which delegated-act changes are visible in the official cited sources?

The cited sources support a narrow list of changes and milestones. The Commission delegated-acts page was last updated on 17 March 2026 and 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.

For current-status language, avoid saying that a proposal is already binding unless the official page or EUR-Lex act shows adoption, publication, and entry into force. The March 2026 feedback items in the source support were explicitly described as proposed amendments that were not yet adopted and not in force.

  • 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; source support does not support treating them as adopted.
Citations
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 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.
Citations
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 with ref=sorena.io 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.
Citations
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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Primary sources

References and citations

Commission Delegated Regulation (EU) 2026/73
eur-lex.europa.eu
Referenced sections
  • Binding example of a multi-act amendment, including its 1 January 2026 application date and transition option for financial years starting in 2025.
"It shall apply from 1 January 2026"
Regulation (EU) 2020/852 (Taxonomy Regulation)
eur-lex.europa.eu
Referenced sections
  • Binding Taxonomy source for delegated-act entry into force, the Parliament and Council objection period, and Commission review of screening criteria.
"enter into force only if no objection"
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