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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.

The main mistake is treating 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 grounding data 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.

The grounding set supports 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 grounding 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. That makes the review log part of the evidence file, not a one-time legal note.

Keep the review evidence specific enough that a later reviewer can see why a conclusion changed or why no change was needed. The file 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. That makes the eligibility-vs-alignment distinction a data lineage issue: the financial KPI should show whether the underlying activity or exposure is non-eligible, eligible but not aligned, or aligned.

The evidence pack should show both steps. Eligibility evidence should prove why the activity is described in the relevant Taxonomy delegated act. Alignment evidence should prove why the same activity meets the Article 3 conditions and the activity-level technical screening criteria.

The most useful file is a reconciliation record: source activity description, internal activity or exposure, KPI denominator and numerator treatment, alignment test result, and the reason any eligible amount was excluded from aligned amounts.

The common mistake is to say that an eligible activity is Taxonomy-aligned without completing the alignment test. Eligibility only says the activity is covered by the Taxonomy activity list. Alignment says the activity satisfies the sustainability conditions and the activity-specific criteria.

A second mistake is to keep only the final KPI table. Reviewers need the mapping and test evidence behind the table, especially where an activity is eligible but not aligned, or where only part of CapEx, OpEx, turnover, or an exposure is allocated to aligned activity.

Article 8 of Regulation (EU) 2020/852 requires undertakings that must publish non-financial information under Articles 19a or 29a of Directive 2013/34/EU to disclose how and to what extent their activities are associated with environmentally sustainable economic activities. Article 8 names turnover, CapEx, and OpEx for non-financial undertakings, then requires a delegated act to specify the content, presentation, and methodology, including the specificities of financial undertakings.

The Disclosures Delegated Act explains why the non-financial turnover, capital expenditure, and operating expenditure KPIs are not appropriate for lending, investment, and insurance activities. It therefore sets separate KPI frameworks for asset managers, credit institutions, investment firms, and insurance and reinsurance undertakings.

For credit institutions subject to Articles 19a and 29a of Directive 2013/34/EU, the Disclosures Delegated Act identifies the Green Asset Ratio as the main KPI. It is intended to show the proportion of exposures related to Taxonomy-aligned activities compared with the credit institution's total assets.

The delegated act links the GAR to the institution's main lending and investment business, including loans, advances, debt securities, and equity holdings. For credit exposures to financial undertakings, the numerator is based on counterparties' KPIs calculated under the same delegated regulation; for credit institutions as counterparties, that means using the counterparty's total GAR.

The Disclosures Delegated Act phased in reporting. Non-financial undertaking KPIs applied from 1 January 2023, while financial undertaking KPIs applied from 1 January 2024. Credit institution KPIs for the trading book and for commission and fee income for commercial services and activities other than financing apply from 1 January 2026.

Some exposures are excluded from the financial undertaking KPI numerator or from both numerator and denominator. Central governments, central banks, and supranational issuers are excluded from both the numerator and denominator. Derivatives are excluded from the numerator. Exposures to undertakings not obliged to publish non-financial information under Articles 19a or 29a of Directive 2013/34/EU are excluded from the numerator.

The financial undertaking KPI number is not enough on its own. Annex XI requires qualitative disclosures to support the quantitative KPIs and market understanding of them.

Useful evidence should therefore explain what assets and activities the KPI covers, which data sources were used, what limitations exist, how Taxonomy-aligned economic activities evolved over time from the second year of implementation, and how the undertaking treats Taxonomy compliance in business strategy, product design, and engagement with clients and counterparties.

For an economic activity to qualify as environmentally sustainable under Article 3, it must make a substantial contribution, do no significant harm to the environmental objectives, and be carried out in compliance with the minimum safeguards in Article 18.

Article 18 makes the test procedural and activity-linked: the undertaking carrying out the economic activity needs procedures that ensure alignment with the OECD Guidelines and the UN Guiding Principles, including the ILO and International Bill of Human Rights references named in the article.

Article 18 names the OECD Guidelines, the UN Guiding Principles, ILO fundamental conventions, and the International Bill of Human Rights. The Platform final report filters those references into four practical minimum-safeguards topics: human rights including labour and consumer rights, bribery and corruption, taxation, and fair competition.

That means a useful review should test whether the undertaking has procedures and evidence for responsible business conduct, not just whether a human-rights policy exists somewhere on the website.

The Article 18 requirement sits with the entity performing the economic activity and claiming that the activity is Taxonomy-aligned. For financial undertakings calculating KPI exposure to other undertakings, Commission guidance says the minimum-safeguards evidence is normally obtained as adequate documentary evidence from the undertaking to which they are exposed.

Financial undertakings should apply the safeguard procedures to their own services only where the financial service itself is Taxonomy-eligible and the undertaking claims that service as Taxonomy-aligned. The grounding material gives examples around certain transport financing descriptions and non-life insurance and reinsurance underwriting activities.

Keep evidence that a reviewer can follow from the Article 18 source to the activity, undertaking, procedures, risk topics, and final alignment claim. A policy PDF alone is weak if it does not show whether the undertaking has implemented and operated relevant due-diligence or governance procedures.

The evidence file should be narrow enough to support the specific Taxonomy claim and clear enough to be reused by finance, sustainability, legal, and assurance teams without reinterpreting the source material.