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Across 13 modules • Updated Jul 24, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
EU Taxonomy minimum safeguards FAQ: Article 18 evidence

What is the common mistake with EU Taxonomy minimum safeguards?

A frequent error is to describe an activity as Taxonomy-aligned because the environmental criteria appear satisfied while treating minimum safeguards as a generic group-policy check. Article 3 makes minimum safeguards a separate condition, so a failed or unresolved safeguards assessment prevents the activity from entering an aligned KPI numerator.

Another error is turning non-binding advice into law. Article 18 is the legal anchor. Commission notices explain the Commission's interpretation but do not bind the Court of Justice, and the Platform report is technical advice.

  • Do not publish broad claims such as 'minimum safeguards met' without activity-level evidence.
  • Do not cite a non-binding report without also anchoring the claim in Article 18 where the legal rule is needed.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 through the sustainability-reporting scope in Articles 19a and 29a of the Accounting Directive. Confirm the reporting entity and consolidation boundary under the current Accounting Directive before calculating the KPIs; the Taxonomy page cannot determine whether a particular undertaking is in scope without those facts.

The three KPIs are turnover, CapEx, and OpEx. Eligibility asks whether an activity is described in a Taxonomy delegated act. Alignment adds the Article 3 tests: substantial contribution, DNSH, minimum safeguards, and compliance with the applicable technical screening criteria.

  • 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?

Calculate each KPI as an aligned numerator divided by its specified denominator, then disclose eligible and aligned proportions in the templates. Use one controlled activity inventory, but do not assume that the three numerators contain the same items.

Turnover uses net turnover. The CapEx denominator covers specified additions to tangible and intangible assets before depreciation, amortisation, and remeasurement, including qualifying additions from business combinations. The OpEx denominator is narrower than total operating expenses: it covers direct non-capitalised costs for research and development, building renovation, short-term leases, maintenance and repair, and day-to-day servicing of property, plant, and equipment.

  • Turnover KPI: aligned net turnover from products or services divided by total net turnover. Adaptation turnover is excluded unless the activity is enabling or is itself Taxonomy-aligned under the conditions in Annex I.
  • CapEx KPI: qualifying aligned CapEx divided by the specified asset-additions denominator. Numerator routes cover aligned activities, a qualifying CapEx plan, and specified purchases or individual measures implemented and operational within 18 months.
  • OpEx KPI: qualifying aligned direct non-capitalised costs divided by the narrow OpEx denominator. Research and development already counted in CapEx cannot be counted again as OpEx.
  • For a CapEx plan, retain management-body approval, the activity-level measures, timing, costs, and the route to alignment. The normal completion period is five years; a longer period requires the delegated act's specific justification and cannot exceed ten years.
Citations
EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx

What evidence should sit behind non-financial Taxonomy KPIs?

The evidence file should let a reviewer trace each public percentage to the applicable rule, activity assessment, accounting record, allocation, and consolidation adjustment. Keep eligible, aligned, non-aligned, and not-assessed amounts separate.

Regulation (EU) 2026/73 permits a non-financial undertaking to omit assessment of activities whose cumulative turnover, CapEx, or OpEx is below 10% of that KPI's denominator. Apply the threshold separately to each KPI, report the omitted amounts as non-material, identify their sectors, and explain why they are non-material. An activity that is material for a KPI must be assessed in full for that KPI.

  • 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 the materiality calculation separately for turnover, CapEx, and OpEx, with the activities omitted and their separately reported amounts.
  • 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?

Do not treat a non-financial Taxonomy KPI as any sustainability metric. The mandatory set is turnover, CapEx, and OpEx, calculated under the delegated-act methodology.

Do not lose the link between the activity assessment and the financial amount. The 2026 templates allow an activity's contribution to several objectives to appear on its activity row, but the same aligned amount must not be double-counted in the summary KPI.

  • 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 apply one 10% materiality calculation across all three KPIs or omit only part of an activity that is material for the KPI.
  • For a financial year beginning in 2025, document whether the undertaking uses the rules applicable on 31 December 2025 or Regulation (EU) 2026/73. Commission Notice C/2026/2558 says the selected rule set must be applied in full and identified in contextual information. For later financial years, use the amended rules.
Citations
EU Taxonomy Six Environmental Objectives

What are the six environmental objectives under the EU Taxonomy?

The six environmental objectives below use Article 9's legal wording. Articles 10 to 15 explain what substantial contribution means for each objective, while Article 17 defines significant harm.

An activity is aligned only if all four Article 3 conditions are met: substantial contribution to one or more objectives, no significant harm to the other objectives, compliance with minimum safeguards, and compliance with 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

What does each objective cover?

Articles 10 to 15 give each objective a distinct legal scope. Use those articles to understand the objective, then use the delegated act for the activity-specific threshold or condition.

  • Climate change mitigation covers avoiding or reducing greenhouse-gas emissions or increasing removals, including listed routes such as renewable energy, energy efficiency, clean mobility, carbon capture, and carbon sinks.
  • Climate change adaptation covers solutions that substantially reduce current or expected future climate risk to the activity, people, nature, or assets without increasing risk elsewhere. An activity can also enable adaptation by others.
  • Water and marine resources covers good status of water bodies, preventing deterioration, sustainable water use, wastewater management, marine protection, and related ecosystem services.
  • Circular economy covers resource efficiency, durability, reparability, reuse, recycling, waste prevention, and keeping products, materials, and resources in use.
  • Pollution prevention and control covers preventing or reducing pollutant releases to air, water, or land, improving environmental quality, managing chemicals, and cleaning pollution without creating new significant harm.
  • Biodiversity and ecosystems covers protecting, conserving, and restoring ecosystems, habitats, species, soils, forests, and ecosystem services.
Citations
EU Taxonomy Six Environmental Objectives

How should teams use the objectives in an assessment?

Identify the economic activity and match it to a delegated-act activity description. A NACE code can help locate a section, but the activity description controls eligibility. If no delegated act covers the activity for an objective, a general environmental benefit does not make it Taxonomy-eligible for that objective.

For every claimed aligned amount, record the substantial-contribution objective, the activity-specific criteria, DNSH results for the other objectives, minimum safeguards, and the reporting period. Article 17 requires life-cycle impacts to be considered, while the delegated act states the evidence and thresholds for the specific activity.

  • Define the activity boundary, operator, site or asset, reporting period, and financial amount.
  • Match the activity description and delegated-act section for each potentially eligible objective.
  • Test every substantial-contribution and DNSH criterion; do not offset a failed DNSH test with a strong contribution to another objective.
  • Assess minimum safeguards for the undertaking carrying out the activity.
  • Keep unresolved criteria and unsupported amounts outside the aligned numerator.
Citations
EU Taxonomy Six Environmental Objectives

Which delegated acts relate to the six objectives?

Delegated Regulation (EU) 2021/2139, the Climate Delegated Act, contains technical screening criteria for climate change mitigation and adaptation. Regulation (EU) 2022/1214 added specified gas and nuclear activities, and Regulation (EU) 2023/2485 added further climate activities.

Delegated Regulation (EU) 2023/2486 is the Environmental Delegated Act for water and marine resources, circular economy, pollution prevention and control, and biodiversity and ecosystems. Regulation (EU) 2026/73 later amended disclosure rules and simplified certain DNSH criteria. Use the consolidated text applicable to the reporting period.

  • 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 traces the activity to its substantial-contribution objective, delegated-act section, DNSH checks, safeguards conclusion, and reported amount. A general sustainability narrative cannot replace the activity-specific criteria.

If one activity substantially contributes to more than one objective, preserve the objective-level assessment but avoid double-counting the same turnover, CapEx, or OpEx in the summary KPI. The reporting templates and instructions applicable to the reporting period control presentation.

  • 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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