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EU Taxonomy Regulation Non-financial KPI reporting under Article 8

In-scope non-financial undertakings report three EU Taxonomy KPIs: turnover, capital expenditure, and operating expenditure.

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
Jul 24, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
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, 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.
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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.
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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, 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.
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Recommended next step

Turn EU Taxonomy KPI reporting into an evidence workflow

Connect each KPI numerator and denominator to its activity assessment, accounting record, allocation, materiality decision, owner, and review evidence.

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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.
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