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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.

Do not describe every review as a mandatory audit. The Commission's Climate Delegated Act notice says some technical screening criteria contain specific verification requirements for certain activities; where the criteria require verification, the external verifier's report is evidence of compliance. For other activities, the file still needs enough documentation to let a reviewer trace the eligibility, alignment, DNSH, safeguards, and KPI decisions.

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.

For Article 8 reporting, non-financial undertakings disclose turnover, CapEx, and OpEx proportions associated with environmentally sustainable economic activities. The Disclosures Delegated Act also requires contextual information for financial undertakings, including scope, data sources, and limitations, so evidence should preserve the source and limitations behind each KPI.

Where Regulation (EU) 2026/73 is used to leave non-material activities unassessed, the review file should not imply that those activities failed eligibility or alignment. Retain the relevant KPI denominator, the cumulative 10% test, the activities omitted from assessment, and the amount reported separately as non-material.

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.

Evidence depth should match the criterion. For example, the Commission notice discusses adequate evidence for building top-15-percent assessments, coherent adaptation plans for DNSH climate adaptation where climate risks are identified, and supplier information or testing for some Appendix C pollution-prevention checks.

A broad sustainability policy does not prove that a specific activity is Taxonomy-aligned. It does not show how the activity met the relevant technical screening criteria, DNSH checks, minimum safeguards, and KPI allocation rules.

A stronger file is narrower and more traceable: it names the activity, the criteria version, the reporting period, the data source, the calculation or allocation method, the reviewer, and the unresolved limitations. For CapEx allocated across mixed-use assets, the Commission notice says the allocation methodology should be based on verifiable evidence.

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.

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 CapEx plan expenditure or Taxonomy-aligned CapEx.

The plan must aim either to expand Taxonomy-aligned economic activities or to upgrade Taxonomy-eligible economic activities so they become Taxonomy-aligned within five years. A longer period is allowed only where objectively justified by specific features of the activity and upgrade, with a maximum of 10 years.

The plan also has to be disclosed at economic-activity aggregated level and approved by the management body of the non-financial undertaking, directly or by delegation. Commission guidance says the five-to-ten-year period starts from that approval.

The evidence should connect the legal route to the accounting amount. Annex I defines the CapEx denominator by reference to additions to tangible and intangible assets during the financial year, and the undertaking should explain how CapEx was determined, allocated to the numerator, and linked to related line items.

For CapEx plan items, keep a register that can be read at activity level. The Commission Notice says different CapEx items under points (a), (b), and (c) of Section 1.1.2.2 must be presented at activity level, with values explained in the specifications and contextual information.

If relevant technical screening criteria are amended before completion of the CapEx plan, Annex I requires the undertaking either to update the plan within two years so the activities are aligned with the amended criteria at completion, or to restate the CapEx KPI numerator. Updating the plan restarts the plan period.

If the CapEx plan fails to meet the stated conditions, the previously published CapEx KPI must be restated. Teams should therefore monitor delegated-act changes, plan delays, scope changes, and implementation changes during each reporting cycle.

Do not treat a broad transition budget, green-finance deck, or capital-allocation narrative as a Taxonomy CapEx plan without the Annex I evidence. A useful public answer should say which activity is affected, which CapEx route applies, what approval exists, what measures are planned, and how the amount flows into the KPI.

Teams should also avoid overclaiming. Eligibility does not prove alignment, a financing source does not make CapEx aligned, and prepayments should not be counted until the related CapEx is recognised under the relevant accounting standards.

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 technical screening criteria and Article 8 disclosure information through delegated acts, 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.

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.

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 technical screening criteria should be regularly reviewed and, where appropriate, delegated acts amended in line with scientific and technological developments. Keep that review log in the evidence file so later reviewers can trace each version decision.

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.

Taxonomy eligibility is about coverage. For Article 8 reporting, teams first map an economic activity to the activities described in the Taxonomy delegated acts and classify it as eligible or non-eligible for the relevant KPI or exposure.

Taxonomy alignment is a higher bar. Article 3 says an economic activity qualifies as environmentally sustainable only where it contributes substantially to one or more Article 9 environmental objectives, does no significant harm to the other objectives, complies with minimum safeguards, and meets the technical screening criteria established by the Commission.

For non-financial undertakings, Article 8 focuses on the proportions of turnover, capital expenditure, and operating expenditure associated with environmentally sustainable economic activities. The Disclosures Delegated Act and Commission FAQ explain that eligibility is reported before or alongside alignment, but eligibility reporting is not the same as proving alignment.

For financial undertakings, the Article 8 framework uses financial KPIs that look through to financed or invested activities. The financial KPI should show whether the underlying activity or exposure is non-eligible, eligible but not aligned, aligned, or left unassessed under a specific reporting option.

Regulation (EU) 2026/73 adds a separate state from 1 January 2026: non-assessed because the activity or exposure is considered non-material under a KPI-specific option. For non-financial undertakings, the cumulative turnover or CapEx threshold is 10% of the respective denominator, with a corresponding rule for material OpEx. These amounts stay in the denominator and are reported separately; they must not be relabelled as eligible, aligned, non-aligned, or non-eligible.