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Across 12 modules • Updated May 27, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
May 27, 2026
EU Taxonomy minimum safeguards FAQ: Article 18 evidence

What is the common mistake with EU Taxonomy minimum safeguards?

The common mistake is to report or describe an activity as Taxonomy-aligned because the environmental criteria look satisfied, while treating minimum safeguards as a generic group policy statement. Article 3 requires the aligned activity to satisfy minimum safeguards as a separate condition.

Another mistake is citing Platform or draft Commission material as binding law. Use Article 18 as the legal anchor, label Platform material as advice, and label draft Commission notices as guidance or draft material where the source is a draft.

  • Do not publish broad claims such as 'minimum safeguards met' without activity-level evidence.
  • Do not cite a non-binding report without also anchoring the claim in Article 18 where the legal rule is needed.
  • Do not reuse evidence from one undertaking or business relationship for another unless the source and facts support reuse.
  • Do not report aligned KPIs where the minimum-safeguards evidence is missing or unresolved.
Citations
EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx

Which non-financial KPIs does Article 8 require?

Article 8 of Regulation (EU) 2020/852 applies to undertakings that are required to publish non-financial information under Article 19a or 29a of the Accounting Directive. Those undertakings must include information on how and to what extent their activities are associated with environmentally sustainable economic activities.

For non-financial undertakings, Article 8 identifies three KPI families: the proportion of turnover from products or services associated with qualifying economic activities, and the proportions of capital expenditure and operating expenditure related to assets or processes associated with those activities.

  • Do not treat generic ESG, operational, or impact indicators as substitutes for the Article 8 KPI set.
  • Start with the reporting entity and consolidation boundary before calculating activity-level figures.
  • Document which activities are Taxonomy-eligible, which are Taxonomy-aligned, and which financial line items feed the turnover, CapEx, and OpEx KPIs.
Citations
EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx

How should teams prepare the turnover, CapEx, and OpEx KPI records?

Build each KPI record from the same controlled activity inventory. For every economic activity, keep the activity description, the Taxonomy objective assessed, the technical screening criteria used, the eligibility or alignment conclusion, and the financial amounts included or excluded.

The Disclosures Delegated Act is the methodology anchor. The Commission's delegated-acts page describes it as the act that specifies the content and presentation of the information to be disclosed and the methodology for the Article 8 obligation.

  • Turnover KPI: trace the reported amount to products or services associated with qualifying economic activities.
  • CapEx KPI: trace the reported amount to assets, processes, eligible activity expansion, aligned activity upgrade, or individual measures only where the delegated-act methodology supports that treatment.
  • OpEx KPI: retain the accounting source, activity link, inclusion rationale, and any exclusion rationale so reviewers can reproduce the calculation.
Citations
EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx

What evidence should sit behind non-financial Taxonomy KPIs?

A useful evidence file lets a reviewer move from the public KPI back to the source rule, activity assessment, and financial data. It should show the reporting scope, the activity mapping, the objective assessed, the screening criteria and DNSH/minimum-safeguards conclusion where alignment is claimed, and the calculation source for each KPI.

Where voluntary Taxonomy information is published alongside mandatory Article 8 reporting, the Commission notice says the basis of preparation should be clear and the voluntary information should not contradict, misrepresent, or be more prominent than the mandatory information.

  • Keep the legal source and Article 8 or delegated-act section used for each decision.
  • Keep the accounting source and reconciliation path for the turnover, CapEx, and OpEx amounts.
  • Keep the activity-level eligibility and alignment assessment, including why excluded activities or amounts were left out.
  • Keep a separate voluntary-reporting note when additional Taxonomy information is published outside the mandatory KPI set.
Citations
EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx

What are common mistakes in non-financial KPI reporting?

The most common mistake is using the phrase non-financial KPI as if it meant any sustainability metric. In Article 8 Taxonomy reporting, the non-financial undertaking KPI set is specific: turnover, CapEx, and OpEx, calculated and presented under the delegated-act methodology.

A second mistake is losing the link between the activity assessment and the financial number. If an activity contributes to more than one environmental objective, teams need a documented approach that avoids double-counting and follows the relevant Commission guidance.

  • Do not publish a Taxonomy-aligned percentage unless the activity assessment and KPI calculation both support it.
  • Do not mix mandatory Article 8 KPIs with voluntary Taxonomy metrics without explaining the basis and relative status of each.
  • Do not count turnover from an activity adapted to climate change unless the delegated-act and Commission-notice conditions for counting that turnover are met.
  • Do not rely on stale templates when the reporting templates or delegated-act amendments applicable to the reporting year have changed.
Citations
EU Taxonomy Six Environmental Objectives

What are the six environmental objectives under the EU Taxonomy?

The six environmental objectives are the Article 9 objectives in the Taxonomy Regulation. Use the exact legal wording when building a control, disclosure, data model, or customer-facing explanation.

The objectives are not the same thing as Taxonomy alignment. An activity still needs to satisfy the Article 3 conditions: substantial contribution to one or more objectives, no significant harm to the other objectives, minimum safeguards, and the applicable technical screening criteria.

  • Climate change mitigation.
  • Climate change adaptation.
  • The sustainable use and protection of water and marine resources.
  • The transition to a circular economy.
  • Pollution prevention and control.
  • The protection and restoration of biodiversity and ecosystems.
Citations
EU Taxonomy Six Environmental Objectives

How should teams use the objectives in an assessment?

Start by mapping the economic activity to the objective it may substantially contribute to. Then check whether the activity causes significant harm to any of the other Article 9 objectives, because the Regulation treats DNSH as a separate condition from substantial contribution.

The assessment should stay activity-specific. A business line, product, project, or supplier category should not be described as Taxonomy-aligned just because it relates to one of the six objectives; the applicable technical screening criteria still decide the contribution and DNSH tests.

  • Identify the economic activity being assessed and the objective or objectives it may substantially contribute to.
  • Find the applicable technical screening criteria in the relevant delegated act before making an alignment statement.
  • Record the DNSH check against the other environmental objectives, including life-cycle considerations where the criteria require them.
  • Confirm minimum safeguards separately; they are part of Article 3 and are not replaced by environmental evidence.
Citations
EU Taxonomy Six Environmental Objectives

Which delegated acts relate to the six objectives?

The Climate Delegated Act sets technical screening criteria for activities that can substantially contribute to climate change mitigation or climate change adaptation. The Environmental Delegated Act addresses the four non-climate objectives: water and marine resources, circular economy, pollution prevention and control, and biodiversity and ecosystems.

Teams should therefore avoid using the six-objective list as a shortcut for criteria selection. The right next step is to match the activity description to the relevant delegated-act section and then assess the criteria that apply to that activity.

  • Climate objectives: climate change mitigation and climate change adaptation.
  • Non-climate objectives: water and marine resources, circular economy, pollution prevention and control, biodiversity and ecosystems.
  • Technical screening criteria can differ even where activity descriptions look similar across delegated acts.
  • Commission FAQ material is useful for interpretation, but the underlying regulation and delegated acts remain the sources to cite for criteria.
Citations
EU Taxonomy Six Environmental Objectives

What evidence should teams keep for the objective mapping?

Keep evidence that lets a reviewer trace the path from the activity to the objective, the delegated-act criteria, the DNSH checks, and the final statement. A generic sustainability narrative is not enough for Taxonomy work.

For Article 8 reporting, the Regulation links disclosures to how and to what extent an undertaking's activities are associated with economic activities that qualify as environmentally sustainable under Articles 3 and 9. That makes objective mapping a disclosure input, not just a policy exercise.

  • Activity description and boundary used for the assessment.
  • Article 9 objective or objectives selected for substantial-contribution review.
  • Delegated-act section and technical screening criteria used.
  • DNSH evidence for the other Article 9 objectives.
  • Minimum-safeguards evidence or unresolved-safeguards note.
  • Disclosure or public-claim text that depends on the assessment.
Citations
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