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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.

Do not call an eligible activity Taxonomy-aligned before 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. Regulation (EU) 2026/73 later deferred credit institution KPIs for the trading book and for commission and fee income from commercial services and activities other than financing to 1 January 2028.

For a financial year beginning in 2025, an undertaking may use either the amended rules or the rules applicable on 31 December 2025. Commission Notice C/2026/2558 explains that an undertaking choosing the earlier rules must apply that rule set in full and identify the rule set in its contextual information; it should not combine selected parts of the two versions.

Regulation (EU) 2026/73 also changes the denominator. Derivatives, cash and cash equivalents, on-demand interbank loans, goodwill, commodities, and other asset categories outside Article 7(6) are excluded from financial-undertaking KPI denominators. Exposures to undertakings outside Articles 19a and 29a reporting are generally excluded from both numerator and denominator, subject to the act's rules for voluntarily reported counterparty KPIs and known use-of-proceeds financing. Central governments, central banks, and supranational issuers remain excluded from numerator and denominator.

The 2026 act adds KPI-specific 10% non-materiality options. For the credit institution GAR, on-balance-sheet assets with known use of proceeds may be left unassessed where their cumulative value is below 10% of all such assets included in the GAR denominator; they must be reported separately as non-material. Until 31 December 2027, a financial undertaking that makes no Taxonomy association claim can instead use the prescribed management-report statement route, subject to Article 7(9).

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.

No. Eligibility only means that an economic activity matches one of the activity descriptions added by Delegated Regulation (EU) 2022/1214. Alignment still requires the four Article 3 conditions: substantial contribution to at least one environmental objective, no significant harm to the other objectives, compliance with Article 18 minimum safeguards, and compliance with the applicable technical screening criteria.

The nuclear sections cover pre-commercial advanced technologies with minimal fuel-cycle waste, new nuclear installations whose construction permit is issued by 2045, and modifications of existing installations intended to extend safe operation where the project is authorised by 2040. The gas sections cover electricity generation, high-efficiency cogeneration, and heat or cooling in an efficient district system.

These are transitional activities under Article 10(2), not a finding that every gas or nuclear activity is sustainable. Match the operating facts to Sections 4.26 to 4.31 and use the criteria that apply to the reporting period.

Nuclear alignment depends on project, operator, and Member State evidence. The common criteria cover nuclear-safety and radioactive-waste law, decommissioning and waste-management funds, disposal capacity for very low-, low-, and intermediate-level waste, and a detailed plan for a high-level-waste disposal facility to operate by 2050.

For electricity generation, life-cycle greenhouse-gas emissions must be below 100 g CO2e/kWh and independently verified using a method permitted by the act. The project must also meet its section's permitting date, safety, accident-tolerant-fuel, reporting, water, waste, pollution, and biodiversity conditions.

Each gas activity has a route based on life-cycle greenhouse-gas emissions below 100 g CO2e/kWh or, for facilities whose construction permit is granted by 31 December 2030, a transition route with additional conditions. For electricity generation under Section 4.29, that route uses direct emissions below 270 g CO2e/kWh or annual direct emissions averaging no more than 550 kg CO2e per kW of capacity over 20 years. Sections 4.30 and 4.31 require direct emissions below 270 g CO2e/kWh of output energy.

The transition routes also require evidence that renewable alternatives are not available, replacement of a more emissions-intensive solid- or liquid-fossil-fuel activity, a full switch to renewable or low-carbon gaseous fuels by 31 December 2035, and at least a 55% emissions reduction. Section 4.29 permits newly installed capacity up to 15% above the replaced facility and measures the reduction over the lifetime of the new capacity; Sections 4.30 and 4.31 do not permit a capacity increase and measure the reduction per kWh of output energy. Each section adds its own efficiency, cogeneration, district-heating, verification, and DNSH conditions.

Build the evidence file at project, activity, and site level. Start with the delegated-act section and version used. Map every criterion to a named record, calculation, permit, plan, technical study, operating record, contractual commitment, or independent assessment. For a future deadline or continuing condition, record the owner, monitoring frequency, and event that would require reassessment.

Do not collapse substantial contribution and DNSH into one generic engineering opinion. The reviewer should be able to see which criterion each document supports, the measurement period and boundary, assumptions or data limitations, and whether the evidence existed at the disclosure reference date.

Article 8 disclosures must identify whether the undertaking carries out, funds, or has exposures to the covered nuclear and gas activities and separately show the required eligible and aligned proportions. Regulation (EU) 2026/73 shortened the wider reporting templates but retained separate gas- and nuclear-related information.

Reconcile each activity-level decision to the relevant turnover, CapEx, OpEx, asset, exposure, investment, or underwriting calculation. Preserve excluded and non-aligned amounts so the disclosure does not imply that one covered activity makes an entire entity, asset, fund, or portfolio aligned.

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 activity must have implemented procedures that ensure alignment with the named standards. A policy statement, code of conduct, certification, or absence of a public allegation does not by itself establish that those procedures exist and operate.

Article 18 names the OECD Guidelines, the UN Guiding Principles, the ILO fundamental conventions, and the International Bill of Human Rights. The Commission has explained that the references to the OECD Guidelines and UN Guiding Principles are dynamic, so the current OECD Guidelines apply. The OECD issued its latest Guidelines in 2023.

The Platform final report groups the source standards into four practical topics: human rights, including labour and consumer rights; bribery and corruption; taxation; and fair competition. That grouping is non-binding advice, but it provides a useful review structure.

The Article 18 requirement applies to the entity performing the economic activity and claiming that activity as Taxonomy-aligned. A group policy may support the assessment, but the evidence must still cover the undertaking that carries out the reported activity.

For KPI exposures to other undertakings, financial undertakings should obtain adequate documentary evidence that those undertakings meet the safeguards. For known-use-of-proceeds retail-client and public-authority exposures, Commission guidance points instead to evidence from the producer or service provider. A financial undertaking applies Article 18 to its own service only where that service is itself Taxonomy-eligible and claimed as aligned, including specified transport financing and non-life insurance or reinsurance underwriting activities.

Keep evidence that traces the Article 18 rule to the activity, the undertaking carrying it out, the implemented procedures, relevant impacts and business relationships, and the final alignment conclusion. The file should show how risks were identified, what action was taken, how results were tracked, and how affected people can obtain remedy where the undertaking caused or contributed to harm.

Record unresolved cases instead of converting missing evidence into a positive conclusion. The Taxonomy Regulation does not prescribe one official minimum-safeguards form, and the Platform's suggested indicators are advice rather than statutory pass-fail criteria.