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EU Taxonomy Regulation Non-financial KPI reporting under Article 8

In-scope non-financial undertakings report three EU Taxonomy key performance indicators (KPIs): turnover, capital expenditure (CapEx), and operating expenditure (OpEx).

The numerator, denominator, activity assessment, materiality options, and disclosure templates come from the Disclosures Delegated Act as amended by Regulation (EU) 2026/73.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections6 primary sources
Overview

Article 8 requires an in-scope to report the proportions of turnover, CapEx, and OpEx associated with Taxonomy-eligible and Taxonomy-aligned economic activities. Each KPI has its own denominator and numerator. Regulation (EU) 2026/73 applies from 1 January 2026 and adds materiality options and shorter templates.

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4 of 4 questions
Question 1

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, do no significant harm (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.
Question 2

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.

  • : 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.
  • : qualifying aligned CapEx divided by the specified asset-additions denominator. Numerator routes cover aligned activities, a qualifying , and specified purchases or individual measures implemented and operational within 18 months.
  • : 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 , 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.
Question 3

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 to omit assessment of activities whose cumulative turnover or CapEx is below 10% of that KPI's denominator. The corresponding 10% option applies to OpEx where OpEx is material for the business model. 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. Where OpEx is not material for the business model, Article 2(1c) separately permits omission of eligibility and alignment assessment for all OpEx activities, provided the undertaking discloses the total OpEx denominator and explains why OpEx is not material for its business model.

  • 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.
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Question 4

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.
Primary sources

References and citations

Commission Delegated Regulation (EU) 2026/73
eur-lex.europa.eu4 citations
Referenced sections
  • Current binding amendment for materiality options, OpEx relief, shorter templates, and application timing.
  • Binding amendment applying from 1 January 2026 that introduces materiality options and replaces the non-financial undertaking templates.
  • Binding source for the 10% materiality options, separate disclosure of non-material amounts, OpEx relief, and replacement templates.
Show 1 more
  • Binding source for application from 1 January 2026, the financial-year-2025 option, materiality treatment, and replacement templates.
Commission Notice C/2023/305 on the Disclosures Delegated Act
eur-lex.europa.eu4 citations
Referenced sections
  • Official implementation guidance on the non-financial undertaking KPIs.
  • Official guidance on turnover allocation, CapEx plans, OpEx categories, voluntary information, and double-counting.
  • Official guidance on voluntary Taxonomy information, comparative information, and calculation questions.
Show 1 more
  • Official guidance on voluntary reporting, comparative information, allocation, and double-counting.
Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act)
eur-lex.europa.eu3 citations
Referenced sections
  • Delegated act specifying KPI formulas, accounting scope, CapEx plans, contextual information, and presentation.
  • The Article 8 delegated act specifies the KPI content, presentation, methodology, and accounting links.
  • Primary delegated-act source for KPI formulas, accounting scope, CapEx plans, contextual information, and presentation.
Regulation (EU) 2020/852 (Taxonomy Regulation)
eur-lex.europa.eu3 citations
Referenced sections
  • Binding Article 8 source for the disclosure duty and the turnover, CapEx, and OpEx categories.
  • Article 8 states the disclosure duty and names turnover, capital expenditure, and operating expenditure for non-financial undertakings.
  • Article 8 links turnover, capital expenditure, and operating expenditure to environmentally sustainable economic activities.

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