---
title: "EU Taxonomy FAQ: eligibility, alignment, DNSH, safeguards, and Article 8"
canonical_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/faq"
source_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/faq/items"
author: "Sorena AI"
description: "EU Taxonomy FAQ hub for eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, Article 8 KPIs, delegated acts, and evidence records."
published_at: "2026-05-09"
updated_at: "2026-05-27"
keywords:
  - "EU Taxonomy FAQ"
  - "Regulation (EU) 2020/852"
  - "EU Taxonomy eligibility"
  - "EU Taxonomy alignment"
  - "technical screening criteria"
  - "DNSH"
  - "minimum safeguards"
  - "Article 8 KPIs"
  - "turnover CapEx OpEx"
  - "Green Asset Ratio"
  - "EU Taxonomy"
  - "Taxonomy eligibility"
  - "Taxonomy alignment"
---
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# EU Taxonomy FAQ: eligibility, alignment, DNSH, safeguards, and Article 8

EU Taxonomy FAQ hub for eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, Article 8 KPIs, delegated acts, and evidence records.

*FAQ Hub* *Taxonomy* *EU*

## EU Taxonomy FAQ eligibility, alignment, DNSH, safeguards, and Article 8 reporting

Direct answers for teams deciding whether an economic activity is Taxonomy-eligible, what is needed for alignment, and what evidence supports Article 8 disclosures.

Use the linked FAQ modules to separate delegated-act activity mapping, technical screening criteria, do-no-significant-harm checks, Article 18 minimum safeguards, and KPI reporting.

The EU Taxonomy is the EU classification system for environmentally sustainable economic activities. This FAQ hub is for legal, finance, sustainability, product, and portfolio teams that need a practical path from an activity description to eligibility, alignment, evidence, and Article 8 disclosure decisions without treating the Taxonomy as a generic ESG label.

## Browse sub-FAQ modules

### [DNSH Appendix C under the EU Taxonomy: chemicals evidence FAQ](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md)

Practical FAQ on EU Taxonomy DNSH Appendix C chemicals criteria, including SVHCs, CLP hazard classes, the 0.1% w/w threshold, suitable alternatives, and controlled conditions evidence.

- 3 items

### [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md)

source-linked FAQ on EU Taxonomy 2026 simplification, Regulation (EU) 2026/73, Article 8 reporting, DNSH evidence, and limits on unsupported claims.

- 4 items

### [EU Taxonomy activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md)

A practical FAQ on EU Taxonomy activity evidence packs: eligibility, alignment, DNSH, minimum safeguards, KPI traceability, and source-linked review records.

- 4 items

### [EU Taxonomy Article 8 Scope FAQ](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md)

source-linked FAQ on EU Taxonomy Article 8 scope, including who reports, which KPI framework applies, and what evidence teams should retain.

- 4 items

### [EU Taxonomy auditor evidence: what to keep for alignment review](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md)

Practical FAQ on EU Taxonomy auditor evidence: what evidence supports eligibility, alignment, DNSH, minimum safeguards, and Article 8 KPI disclosures.

- 4 items

### [EU Taxonomy CapEx Plans FAQ: Article 8 CapEx KPI](/artifacts/eu/taxonomy-regulation/faq/capex-plans.md)

Practical FAQ on EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2, management-body approval, timing, activity-level evidence, and KPI restatement.

- 5 items

### [EU Taxonomy delegated act changes: what teams should check](/artifacts/eu/taxonomy-regulation/faq/delegated-act-changes.md)

FAQ on handling EU Taxonomy delegated act changes: official source checks, application dates, affected criteria, disclosures, DNSH evidence, and review records.

- 4 items

### [EU Taxonomy eligibility vs alignment: what is the difference?](/artifacts/eu/taxonomy-regulation/faq/eligibility-vs-alignment.md)

Eligibility means an activity is covered by Taxonomy delegated acts; alignment means it also meets Article 3 conditions, technical screening criteria, DNSH, and minimum safeguards.

- 4 items

### [EU Taxonomy Financial KPIs and Green Asset Ratio (GAR) FAQ](/artifacts/eu/taxonomy-regulation/faq/financial-kpis-and-gar.md)

FAQ on EU Taxonomy Article 8 financial undertaking KPIs, credit institution Green Asset Ratio (GAR), reporting dates, exclusions, and qualitative disclosures.

- 4 items

### [EU Taxonomy minimum safeguards FAQ: Article 18 evidence](/artifacts/eu/taxonomy-regulation/faq/minimum-safeguards.md)

FAQ on EU Taxonomy minimum safeguards under Article 18: who must comply, which OECD, UNGP, ILO and human-rights evidence to keep, and common reporting mistakes.

- 5 items

### [EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx](/artifacts/eu/taxonomy-regulation/faq/non-financial-kpis.md)

Article 8 FAQ for non-financial undertakings reporting EU Taxonomy turnover, CapEx and OpEx KPIs, with evidence and source checks.

- 4 items

### [EU Taxonomy Six Environmental Objectives | Article 9 FAQ](/artifacts/eu/taxonomy-regulation/faq/six-environmental-objectives.md)

Plain-English FAQ on the six EU Taxonomy environmental objectives in Article 9 and how teams should map activities, DNSH checks, safeguards, and evidence.

- 4 items

Browse all indexed questions: [/artifacts/eu/taxonomy-regulation/faq/items](/artifacts/eu/taxonomy-regulation/faq/items.md)

## All FAQ items

*Page 1 of 3. Showing 20 of 49 items.*

### [What is DNSH Appendix C under the EU Taxonomy?](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md#what-is-dnsh-appendix-c-under-the-eu-taxonomy)

*Module: [DNSH Appendix C under the EU Taxonomy: chemicals evidence](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md)*

Appendix C to Annexes I and II of Delegated Regulation (EU) 2021/2139 sets generic DNSH criteria for pollution prevention and control where an activity's technical screening criteria refer to that appendix. The Commission FAQ describes it as covering the use and presence of chemicals, especially substances of very high concern and other hazardous substances referred to in EU chemicals legislation.

- Confirm the exact economic activity and annex section before applying Appendix C.
- Keep the Appendix C review tied to the activity's DNSH pollution prevention and control criterion.
- Do not turn Appendix C into a generic chemicals policy claim unless the activity-specific criteria actually call it up.

Sources for this answer:

- [Commission FAQ on EU Taxonomy delegated acts](https://finance.ec.europa.eu/document/download/b799db63-a034-4023-9f77-3e9a69be4de9_en?filename=241129-draft-commission-notice-eu-taxonomy-delegated-acts_en.pdf&ref=sorena.io) - Commission FAQ 133 explains that Appendix C sets generic DNSH criteria for pollution prevention and control relating to use and presence of chemicals.
- [Commission Delegated Regulation (EU) 2023/2485](https://eur-lex.europa.eu/eli/reg_del/2023/2485/oj/eng?ref=sorena.io) - Delegated act amending Appendix C and describing it as generic DNSH criteria for pollution prevention and control.

### [Which substances are covered by the Appendix C amendments?](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md#which-substances-are-covered-by-the-appendix-c-amendments)

*Module: [DNSH Appendix C under the EU Taxonomy: chemicals evidence](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md)*

The 27 June 2023 amendments revised the former "essential use for society" derogation. For point (f), the Commission FAQ says the focus is substances identified as substances of very high concern under REACH Article 57 and Article 59 procedures; those substances are found on ECHA's candidate list.

- Check REACH SVHC status against the ECHA candidate list when point (f) is relevant.
- Check CLP hazard classification for substances covered by the paragraph added after point (f).
- Record whether the conclusion relies on a harmonised classification, a supplier classification, or another documented classification source.

Sources for this answer:

- [Commission FAQ on EU Taxonomy delegated acts](https://finance.ec.europa.eu/document/download/b799db63-a034-4023-9f77-3e9a69be4de9_en?filename=241129-draft-commission-notice-eu-taxonomy-delegated-acts_en.pdf&ref=sorena.io) - Commission FAQs 134 and 135 distinguish SVHCs under REACH from CLP hazard classes and categories mentioned in REACH Article 57, and point readers to ECHA's candidate list and C&L inventory.

### [What evidence is needed for suitable alternatives and controlled conditions?](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md#what-evidence-is-needed-for-suitable-alternatives-and-controlled-conditions)

*Module: [DNSH Appendix C under the EU Taxonomy: chemicals evidence](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md)*

If a covered substance is present and an operator relies on the derogation, Appendix C is not satisfied by a bare statement that the substance is necessary. The Commission FAQ says operators have to assess and document that no other suitable alternative substances or technologies are available on the market and, if there are no such alternatives, that the substances are used under controlled conditions.

- Document the safer, technically feasible, economically feasible, and available tests for each rejected alternative.
- Where a REACH Annex XIV authorisation is relied on, retain the authorisation number, authorisation decision, and required compliance documents.
- For controlled conditions, retain the risk assessment, risk management measures, exposure and emissions controls, and evidence of compliance with relevant legal requirements.
- Do not rely on the 'essential use' concept as the current Appendix C derogation test; the Commission FAQ says the current conditions remain absence of suitable alternatives and use under controlled conditions.

Sources for this answer:

- [Commission FAQ on EU Taxonomy delegated acts](https://finance.ec.europa.eu/document/download/b799db63-a034-4023-9f77-3e9a69be4de9_en?filename=241129-draft-commission-notice-eu-taxonomy-delegated-acts_en.pdf&ref=sorena.io) - Commission FAQs 136 and 137 explain the current derogation conditions and the evidence expected for suitable alternatives and controlled conditions.
- [Commission Delegated Regulation (EU) 2023/2485](https://eur-lex.europa.eu/eli/reg_del/2023/2485/oj/eng?ref=sorena.io) - The delegated act replaced the essential-use framing with no suitable alternatives and controlled-conditions language.

### [What should teams do about EU Taxonomy 2026 simplification?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md#what-should-teams-do-about-eu-taxonomy-2026-simplification)

*Module: [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md)*

Start by identifying which simplification item is being discussed. The source pack supports one adopted 2026 item: Commission Delegated Regulation (EU) 2026/73, described as amending the Disclosures Delegated Act on the content and presentation of information to be disclosed and amending the Climate and Environmental delegated acts for certain DNSH technical screening criteria.

- Confirm whether the question concerns the adopted Regulation (EU) 2026/73 or a later public-feedback item.
- Map the change to Article 8 presentation/content, DNSH technical screening criteria, or both.
- Keep existing Article 3 alignment checks in view: substantial contribution, DNSH, minimum safeguards, and applicable technical screening criteria.
- Record any unsupported request for thresholds, dates, exemptions, or proposal details as an unresolved legal-content gap.

Sources for this answer:

- [European Commission: Implementing and delegated acts - Taxonomy Regulation](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/taxonomy-regulation_en?ref=sorena.io) - Grounds the adopted 2026 simplification item and distinguishes it from March 2026 public feedback that the source says was not yet in force.
- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Grounds the continuing Article 3 criteria that simplification does not erase: substantial contribution, DNSH, minimum safeguards, and technical screening criteria.

### [Does 2026 simplification change Article 8 reporting work?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md#does-2026-simplification-change-article-8-reporting-work)

*Module: [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md)*

The grounded answer is limited: the Commission page describes Regulation (EU) 2026/73 as simplifying the content and presentation of information disclosed concerning environmentally sustainable activities. It does not, in this source pack, support replacing the Article 8 scope analysis or removing the need to explain how and to what extent activities are associated with environmentally sustainable economic activities.

- Retain the source showing why a presentation or content change is allowed.
- Keep numerator, denominator, eligibility, alignment, and limitation notes traceable to the reporting source used.
- Do not remove Article 8 scope evidence merely because the presentation of disclosed information has been simplified.
- Label management assumptions separately from adopted legal text.

Sources for this answer:

- [European Commission: Implementing and delegated acts - Taxonomy Regulation](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/taxonomy-regulation_en?ref=sorena.io) - Identifies Regulation (EU) 2026/73 as a simplification of the content and presentation of disclosed information.
- [Commission Notice 2022/C 385/01 on Article 8 Taxonomy reporting](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52022XC1006%2801%29&ref=sorena.io) - Supports retaining Article 8 scope, eligibility, and implementation evidence unless the adopted simplification source specifically changes it.

### [How should teams treat March 2026 usability proposals?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md#how-should-teams-treat-march-2026-usability-proposals)

*Module: [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md)*

Do not implement a public-feedback item as if it were already binding. The Commission page lists public feedback open from 17 March 2026 until 14 April for proposed delegated regulations on enhancing the usability of technical screening criteria, and it states those items were not yet adopted and not in force until publication in the Official Journal.

- Create a separate watchlist row for public-feedback items.
- Do not change published Taxonomy claims based only on a not-yet-in-force proposal.
- Capture the source status, feedback closing date, affected delegated act, and decision owner.
- Escalate any request to cite proposal thresholds or final implementation dates because this source pack does not provide them.

Sources for this answer:

- [European Commission: Implementing and delegated acts - Taxonomy Regulation](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/taxonomy-regulation_en?ref=sorena.io) - Grounds the March 2026 public-feedback status and the caution that the items were not yet adopted or in force.

### [What evidence should be retained for 2026 simplification?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md#what-evidence-should-be-retained-for-2026-simplification)

*Module: [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md)*

Keep a short evidence pack that can be read by reporting, legal, sustainability, product, and assurance teams without guessing which 2026 item was applied. The pack should show whether the change came from the adopted 2026 delegated regulation or from a monitored proposal that has not yet become binding.

- Source status record: adopted, public feedback, not yet in force, or unresolved.
- Affected workflow: Article 8 content and presentation, DNSH technical screening criteria, or monitored usability proposal.
- Current disclosure or criteria file before the change.
- Approved change note with owner, reviewer, effective source, and review date.
- Exception log for unsupported claims, missing final text, or requests to use proposal material as final law.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Supports retaining evidence for the continuing Article 3 criteria and Article 8 disclosure basis.
- [European Commission: Implementing and delegated acts - Taxonomy Regulation](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/taxonomy-regulation_en?ref=sorena.io) - Supports source-status tracking because the same page separates published delegated acts from public-feedback items.

### [What should teams do about EU Taxonomy activity evidence packs?](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md#what-should-teams-do-about-eu-taxonomy-activity-evidence-packs)

*Module: [EU Taxonomy activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md)*

Create a separate evidence pack for each economic activity that may be reported as Taxonomy-eligible or Taxonomy-aligned. The Regulation defines an environmentally sustainable activity through a four-part test: substantial contribution to at least one environmental objective, no significant harm to the others, minimum safeguards, and compliance with the applicable technical screening criteria.

- Map the business activity to the relevant Taxonomy activity description before testing alignment.
- Separate eligibility evidence from alignment evidence so a listed activity is not mistaken for a compliant one.
- Keep substantial-contribution, DNSH, minimum-safeguards, and technical-screening evidence in the same activity record.
- Record whether the activity affects Article 8 turnover, CapEx, OpEx, financial-undertaking KPI inputs, or voluntary reporting only.
- Name the owner, approver, source version, accounting period, and review trigger for each activity decision.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0852&ref=sorena.io) - Primary legal source for the Article 3 conditions used to decide whether an economic activity qualifies as environmentally sustainable.
- [Commission Notice C/2023/305 on Article 8 Disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Commission implementation guidance distinguishing Taxonomy-eligible and Taxonomy-aligned reporting under the Disclosures Delegated Act.
- [TEG final report on the EU Taxonomy](https://finance.ec.europa.eu/system/files/2020-03/200309-sustainable-finance-teg-final-report-taxonomy_en.pdf?ref=sorena.io) - Explains the practical sequence of activity segmentation, substantial-contribution testing, DNSH checks, and minimum-safeguards due diligence.

### [What should each activity evidence pack contain?](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md#what-should-each-activity-evidence-pack-contain)

*Module: [EU Taxonomy activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md)*

A useful pack should be short enough to maintain but specific enough to support assurance. It should contain the source citation, the business facts used for the activity mapping, the criterion-by-criterion conclusion, the KPI treatment, and the unresolved questions that prevent or limit alignment.

- Activity boundary: product, service, asset, facility, project, counterparty, or revenue stream covered by the assessment.
- Source basis: delegated act, annex, activity name or description, environmental objective, criteria version, and short quote.
- Eligibility conclusion: why the activity is or is not described by an applicable delegated-act activity.
- Alignment conclusion: evidence for substantial contribution, DNSH, minimum safeguards, and technical screening criteria.
- KPI bridge: turnover, CapEx, OpEx, GAR/GIR input, or no KPI impact, with the accounting period and allocation method.
- Review controls: evidence owner, approver, source refresh trigger, and exception note where data is incomplete.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0852&ref=sorena.io) - Article 8 identifies the turnover, CapEx, and OpEx proportions that relevant undertakings disclose for environmentally sustainable activities.
- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Disclosures Delegated Act source for the content, presentation, and methodology of Article 8 Taxonomy disclosures.
- [Commission Notice C/2023/305 on Article 8 Disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Clarifies how non-financial undertakings handle Taxonomy KPIs, activity-level presentation, CapEx plans, allocation, and contextual information.

### [How should teams handle missing or partial evidence?](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md#how-should-teams-handle-missing-or-partial-evidence)

*Module: [EU Taxonomy activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md)*

Do not fill evidence gaps with broad sustainability wording. If the activity is eligible but the team cannot demonstrate substantial contribution, DNSH, minimum safeguards, or a technical screening criterion, the pack should say which condition is unverified and keep the conclusion narrower.

- Mark the activity as eligible only when the delegated-act description is met but alignment evidence is incomplete.
- Do not count turnover as Taxonomy-aligned until the relevant alignment conclusion is supported.
- For CapEx or OpEx, document the plan, measure, timing, allocation basis, and activity-level presentation before including it in the KPI numerator.
- Keep estimates and management judgments separate from third-party records, accounting data, permits, technical test results, or supplier confirmations.
- Escalate outdated delegated-act criteria, missing counterparty KPIs, unresolved DNSH tests, and minimum-safeguards red flags before publication.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0852&ref=sorena.io) - Primary source for the prudent-use principle where complete, reliable, and timely information is not available for limited data elements.
- [Commission Notice C/2023/305 on Article 8 Disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Commission guidance on CapEx plan precision, activity-level presentation, allocation methodology, and verifiable evidence.
- [TEG final report on the EU Taxonomy](https://finance.ec.europa.eu/system/files/2020-03/200309-sustainable-finance-teg-final-report-taxonomy_en.pdf?ref=sorena.io) - Practical guidance that insufficient data should prevent an activity from being treated as Taxonomy-aligned.

### [What is the most common mistake with EU Taxonomy activity evidence packs?](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md#what-is-the-most-common-mistake-with-eu-taxonomy-activity-evidence-packs)

*Module: [EU Taxonomy activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md)*

The common mistake is treating the evidence pack as a generic compliance checklist. That misses the point: Taxonomy reporting is activity-specific, criteria-specific, and KPI-sensitive. A pack that does not identify the activity, criteria, evidence, and disclosure impact will not reliably support a public KPI or an investor-facing explanation.

- Avoid activity packs that cite the Regulation but do not identify the delegated-act activity and criteria applied.
- Avoid mixing eligible, aligned, potentially aligned, and voluntary information in one conclusion.
- Avoid stale screenshots or private working notes when an external legal or Commission guidance URL is the source of the rule.
- Avoid KPI allocations without the non-financial metric, accounting basis, and contextual explanation used to support them.
- Avoid reusing a prior-year conclusion after delegated-act updates, business-model changes, new assets, supplier changes, or assurance findings.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0852&ref=sorena.io) - Primary source establishing common criteria and technical screening criteria to reduce inconsistent green claims and support comparability.
- [Commission Notice C/2023/305 on Article 8 Disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Commission guidance for avoiding misleading voluntary Taxonomy-alignment information and for linking KPI values to contextual information.
- [TEG final report on the EU Taxonomy](https://finance.ec.europa.eu/system/files/2020-03/200309-sustainable-finance-teg-final-report-taxonomy_en.pdf?ref=sorena.io) - Practical source for assessing economic activities rather than relying on broad sector labels or generic sustainability improvements.

### [What is the Article 8 scope test?](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md#what-is-the-article-8-scope-test)

*Module: [EU Taxonomy Article 8 Scope](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md)*

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.

- 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.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852&ref=sorena.io) - Primary source for the Article 8 obligation and its link to Articles 19a and 29a of Directive 2013/34/EU.
- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2178&ref=sorena.io) - Disclosures Delegated Act specifying the content, presentation, and methodology for Article 8 disclosures.
- [European Commission Article 8 Disclosures FAQ](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Commission FAQ explaining implementation of Article 8 reporting by financial and non-financial undertakings.

### [Which KPI framework applies once an undertaking is in scope?](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md#which-kpi-framework-applies-once-an-undertaking-is-in-scope)

*Module: [EU Taxonomy Article 8 Scope](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md)*

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.

- 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.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2178&ref=sorena.io) - Source for non-financial undertaking disclosures, financial undertaking KPI methods, and the definition of Taxonomy-eligible activity.
- [European Commission Article 8 Disclosures FAQ](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Commission FAQ describing the different reporting paths for non-financial and financial undertakings.

### [Where should Article 8 information appear?](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md#where-should-article-8-information-appear)

*Module: [EU Taxonomy Article 8 Scope](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md)*

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.

- 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.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2178&ref=sorena.io) - Source for common disclosure placement, reporting period, and currency requirements.
- [European Commission Article 8 Disclosures FAQ](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Commission FAQ explaining that Article 8 disclosures are reported alongside non-financial or consolidated non-financial statements.

### [What evidence should teams keep for the Article 8 scope decision?](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md#what-evidence-should-teams-keep-for-the-article-8-scope-decision)

*Module: [EU Taxonomy Article 8 Scope](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md)*

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.

- 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.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2178&ref=sorena.io) - Source for undertaking categories, Article 7 exclusions, and common Article 8 disclosure rules.
- [European Commission Article 8 Disclosures FAQ](https://finance.ec.europa.eu/system/files/2022-01/sustainable-finance-taxonomy-article-8-report-eligible-activities-assets-faq_en.pdf?ref=sorena.io) - Commission FAQ supporting practical evidence points for scope, timing, and voluntary disclosures.

### [What should teams do about auditor evidence under the EU Taxonomy Regulation?](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md#what-should-teams-do-about-auditor-evidence-under-the-eu-taxonomy-regulation)

*Module: [EU Taxonomy auditor evidence: what to keep for alignment review](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md)*

Build the evidence file around the four alignment conditions in Article 3 of Regulation (EU) 2020/852: substantial contribution to at least one environmental objective, no significant harm to the other objectives, compliance with minimum safeguards, and compliance with the Commission's technical screening criteria.

- Map the reported activity to the delegated-act activity description and environmental objective before collecting evidence.
- Keep the technical screening criteria applied, the supporting data, and the conclusion for substantial contribution and DNSH in one review record.
- Attach minimum-safeguards evidence that shows procedures aligned with Article 18 references to OECD Guidelines, UN Guiding Principles, ILO fundamental principles and rights, and the International Bill of Human Rights.
- Add verifier reports only where the applicable technical screening criteria or activity-specific guidance requires external verification.

Sources for this answer:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32020R0852&ref=sorena.io) - Defines the Article 3 conditions for an economic activity to qualify as environmentally sustainable and Article 18 minimum safeguards.
- [Commission Notice C/2023/267 on Climate Delegated Act technical screening criteria](https://eur-lex.europa.eu/eli/C/2023/267/oj/eng?ref=sorena.io) - Clarifies that checking compliance with technical screening criteria requires collecting and assessing relevant information, and that verifier reports evidence compliance where verification is required.

### [Which evidence belongs in a review-ready Taxonomy file?](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md#which-evidence-belongs-in-a-review-ready-taxonomy-file)

*Module: [EU Taxonomy auditor evidence: what to keep for alignment review](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md)*

A review-ready file should let a person who was not involved in the original assessment reproduce the conclusion. Start with the activity boundary and the applicable delegated-act criteria, then connect each data point to the published disclosure line or KPI value it supports.

- Activity scoping: legal entity, business line, activity description, objective, and applicable delegated act section.
- Eligibility and alignment matrix: substantial-contribution criteria, DNSH criteria, minimum-safeguards check, and conclusion.
- KPI support: turnover, CapEx, OpEx, GAR, GIR, or other applicable Article 8 calculation support, including allocation logic.
- Data provenance: source systems, external data providers, study references, estimates used, and known data limitations.
- Disclosure bridge: where each evidence item appears in the management report, sustainability statement, Taxonomy table, or narrative explanation.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Specifies Article 8 disclosure content and methodology, including turnover, CapEx, OpEx, and qualitative information for financial undertakings.
- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32020R0852&ref=sorena.io) - Article 8 requires covered undertakings to disclose how and to what extent their activities are associated with environmentally sustainable economic activities.

### [How should teams handle technical screening criteria and DNSH evidence?](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md#how-should-teams-handle-technical-screening-criteria-and-dnsh-evidence)

*Module: [EU Taxonomy auditor evidence: what to keep for alignment review](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md)*

Treat every technical screening criterion as an evidence requirement, even when the criterion does not prescribe a formal verifier. The Climate Delegated Act notice says compliance checking requires collecting and assessing relevant information; it also explains that all substantial-contribution criteria, DNSH criteria, and minimum social safeguards must be met for an activity to be considered Taxonomy-aligned.

- Keep the exact criterion text or citation used for each activity and reporting period.
- Record the data, certificate, technical study, supplier statement, test result, adaptation plan, or verifier report used to support each criterion.
- Separate evidence for substantial contribution from DNSH evidence so a reviewer can see that both tests were performed.
- Reassess dynamic criteria when criteria change or an activity falls out of compliance; do not rely on a stale historic conclusion for current alignment.

Sources for this answer:

- [Commission Notice C/2023/267 on Climate Delegated Act technical screening criteria](https://eur-lex.europa.eu/eli/C/2023/267/oj/eng?ref=sorena.io) - Provides practical interpretation on checking technical screening criteria, verification reports, adequate evidence for building benchmarks, adaptation-plan documentation, and Appendix C evidence examples.
- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32020R0852&ref=sorena.io) - Article 19 says technical screening criteria should facilitate verification of compliance and should be based on evidence, thresholds where possible, and life-cycle considerations.

### [What is the most common mistake with Taxonomy auditor evidence?](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md#what-is-the-most-common-mistake-with-taxonomy-auditor-evidence)

*Module: [EU Taxonomy auditor evidence: what to keep for alignment review](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md)*

The common mistake is presenting a broad sustainability policy as evidence for a specific Taxonomy-aligned activity. That does not show how the activity met the relevant technical screening criteria, DNSH checks, minimum safeguards, and KPI allocation rules.

- Avoid claiming external audit or assurance is required for every Taxonomy decision unless the applicable criterion or reporting rule says so.
- Avoid unsupported allocations of mixed-use CapEx, OpEx, revenue, or assets; preserve the non-financial metric and methodology used.
- Avoid relying on proxies where the Commission guidance says adequate evidence, a technical study, or the specified certificate is needed.
- Avoid dropping data limitations from the final disclosure narrative when they affected the KPI or alignment conclusion.

Sources for this answer:

- [Commission Notice C/2023/305 on Article 8 Disclosures Delegated Act reporting](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - Explains that CapEx allocation to Taxonomy-aligned activities should be accurate and based on verifiable evidence, with contextual information on allocation methodology.
- [Platform Recommendations on Data and Usability](https://finance.ec.europa.eu/system/files/2022-10/221011-sustainable-finance-platform-finance-report-usability_en_1.pdf?ref=sorena.io) - Advisory Platform report discussing verification and assurance questions, data availability, estimates, and usability issues in Taxonomy reporting.

### [When should teams use the CapEx plan route?](/artifacts/eu/taxonomy-regulation/faq/capex-plans.md#when-should-teams-use-the-capex-plan-route)

*Module: [EU Taxonomy CapEx Plans FAQ: Article 8 CapEx KPI](/artifacts/eu/taxonomy-regulation/faq/capex-plans.md)*

Use the CapEx plan 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.

- Confirm the undertaking is reporting Article 8 turnover, CapEx, and OpEx KPIs.
- Map the expenditure to a Taxonomy economic activity and environmental objective.
- Classify the amount as already aligned CapEx, CapEx plan expenditure, or purchase of aligned output and individual measures.
- Use the CapEx plan route for multi-period expansion or upgrade cases where the activity is expected to become Taxonomy-aligned.
- Keep eligibility, alignment, DNSH, minimum safeguards, and CapEx-plan treatment separate in the evidence file.

Sources for this answer:

- [Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Annex I Section 1.1.2.2 defines the CapEx KPI numerator routes, including CapEx plans.
- [Commission Notice C/2023/305 on Article 8 disclosures](https://eur-lex.europa.eu/eli/C/2023/305/oj/eng?ref=sorena.io) - FAQ 26 explains when expansion CapEx should use the CapEx plan route rather than same-period aligned CapEx treatment.
- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0852&ref=sorena.io) - Article 8 requires undertakings in scope to disclose how and to what extent their activities are associated with environmentally sustainable economic activities.

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*Recommended next step*

*Placement: after evidence section*

## Turn EU Taxonomy answers into reportable evidence

Use this EU Taxonomy FAQ hub to connect activity mapping, technical screening criteria, DNSH checks, minimum safeguards, and Article 8 KPI evidence before reporting or publishing sustainability claims.

- [Open Research Copilot](/solutions/research-copilot.md): Answer EU Taxonomy implementation questions with cited source material.
- [Discuss EU Taxonomy implementation](/contact.md): Review activity scope, delegated-act criteria, evidence records, and Article 8 reporting steps with Sorena.


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