TaxonomyArticle 8EU

EU Taxonomy Article 8 KPI disclosure workflow

A practical workflow for preparing EU Taxonomy disclosures from activity mapping through KPI calculation, template population, contextual notes, and review.

Connect finance, sustainability, and reporting controls around turnover, capital expenditure (CapEx), operating expenditure (OpEx), and the Green Asset Ratio (GAR).

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

requires in-scope undertakings to disclose how and to what extent their activities are associated with environmentally sustainable economic activities. Choose the reporting entity type and applicable rule set first, then map activities, calculate the prescribed KPIs, populate the correct templates, and reconcile every public figure to evidence. Regulation (EU) 2026/73 changed materiality options, financial-undertaking denominators, and templates from 1 January 2026.

Section 1

Build the Article 8 KPI inventory before calculating percentages

Start the workflow by identifying which disclosure route applies to the reporting entity. Non-financial undertakings use Annex I and the Annex II templates; asset managers use Annexes III and IV; credit institutions use Annexes V and VI; investment firms use Annexes VII and VIII; insurance and reinsurance undertakings use Annexes IX and X. Financial undertakings also use Annex XI qualitative information.

The first evidence register should record the reporting entity, reporting period, applicable annexes, template owner, source systems, and whether each economic activity is , Taxonomy-aligned, or Taxonomy-non-eligible. Eligibility means the activity is described in the relevant delegated acts, even if it does not meet the technical screening criteria.

  • Confirm whether the entity reports as a non-financial undertaking, asset manager, credit institution, investment firm, insurer, reinsurer, or mixed group.
  • Map each activity to the relevant delegated-act activity description before assessing alignment.
  • Separate activities that meet technical screening criteria from eligible activities that do not meet them.
  • Keep transitional and enabling activity labels where the applicable template or methodology requires them.
  • Assign one owner for each annex template and one reviewer for cross-references in the sustainability information.
  • For a financial year starting in 2025, record whether the undertaking uses the amended rules applying from 1 January 2026 or the rules in force on 31 December 2025. Commission Notice C/2026/2558 says the selected rule set must be applied in full and identified in contextual information.
Section 2

Calculate non-financial undertaking turnover, CapEx, and OpEx KPIs

For non-financial undertakings, disclosures revolve around the proportion of turnover, capital expenditure, and operating expenditure associated with Taxonomy-aligned activities. The workflow should tie each numerator and denominator back to accounting records and the required Annex I methodology, not to an isolated sustainability spreadsheet.

The turnover KPI uses the part of net turnover from products or services associated with Taxonomy-aligned economic activities as numerator and net turnover as denominator. The CapEx denominator covers additions to tangible and intangible assets during the financial year before depreciation, amortisation, remeasurement, and specified fair value effects, while the CapEx numerator is limited to qualifying aligned assets or processes, qualifying CapEx plans, or qualifying purchases of aligned output and individual measures. The OpEx denominator covers direct non-capitalised costs such as research and development, building renovation measures, short-term lease, maintenance and repair, and other direct servicing expenditures; the numerator is the aligned part specified in Annex I.

  • Create one calculation tab for turnover, one for CapEx, and one for OpEx, with line-item references to financial-statement source data.
  • For each numerator entry, record the activity, environmental objective, alignment basis, evidence reference, and whether the amount also appears in another KPI.
  • For CapEx-plan amounts, record the management-body approval, economic activities concerned, environmental objectives, expected timing, total capital expense, and any objective justification for a period beyond five years.
  • Under the amended rules, when OpEx is not material to the business model, disclose the OpEx denominator and explain why it is not material; do not assign eligibility or alignment without assessment.
  • If the amended activity-level threshold is used, calculate cumulative omitted turnover, CapEx, or material OpEx against its own KPI denominator and report each omitted amount separately as non-material.
  • Run a double-counting review across activities and objectives before copying figures into the Annex II templates.
Section 3

Control financial undertaking dependencies and GAR inputs

Financial undertakings need a separate dependency workflow because their KPIs often rely on counterparties' most recently available data and KPIs. Credit institutions, for example, disclose the Green Asset Ratio using methodologies in Annex V, while Article 7 sets common rules for excluded exposures and treatment of specific instruments.

Under the rules applying from 1 January 2026, Article 7 excludes derivatives, cash and cash equivalents, on-demand interbank loans, goodwill, commodities, and other assets outside Article 7(6) from financial-undertaking KPI denominators. It also excludes exposures to undertakings outside Articles 19a or 29a that do not belong to a group covered by those provisions. Qualifying special-purpose vehicle (SPV) exposures remain in scope, and voluntary counterparty KPIs or information may bring otherwise excluded exposures into the denominator and numerator under the specified conditions.

  • Create a counterparty-data log showing source date, turnover KPI, CapEx KPI, GAR or other applicable KPI, and whether the data is eligible for use in the reporting year.
  • Separate denominator exclusions, non-assessed materiality amounts, qualifying SPV exposures, voluntary counterparty reporting, and exceptions.
  • For credit institutions, distinguish GAR for stock and flow where the Annex V methodology requires that distinction.
  • For use-of-proceeds sustainable bonds or debt securities, document the financed activity, investee evidence, amount included, and double-counting adjustment.
  • For voluntary counterparty KPIs or exceptions permitted by amended Article 7(3), keep the counterparty evidence, inclusion rationale, weighting or aligned amount, and double-counting control with the calculation file.
Section 4

Publish Article 8 disclosures with contextual information and template checks

Before publication, the workflow should verify that KPI figures, accompanying disclosures, and cross-references live in the same parts of the non-financial statement as required by of the Disclosures Delegated Act, or that the statement contains clear cross-references to where the accompanying disclosures appear.

For non-financial undertakings, the contextual-information review should cover accounting policy, assessment of compliance with Regulation (EU) 2020/852, contribution to multiple objectives, disaggregation of KPIs, key drivers of turnover changes, CapEx-plan information, and OpEx explanations. If voluntary disclosures are added, they should not contradict or misrepresent mandatory disclosures, should not be more prominent than mandatory disclosures, and should explain the basis, methods, and difference from mandatory reporting.

  • Check that the KPI period is the previous annual reporting period and that the currency matches the financial statements.
  • Confirm that accompanying disclosures are in the same part of the non-financial statement as the KPIs or are cross-referenced there.
  • Verify that Annex II or the applicable financial-undertaking template is populated from controlled calculation files.
  • Review all voluntary information for clear labeling, method disclosure, and consistency with mandatory disclosures.
  • Keep a sign-off record showing calculation owner, source owner, template owner, legal or reporting reviewer, and final publication approver.
Recommended next step

Turn Article 8 KPI rules into a disclosure workflow

This EU Taxonomy guide helps connect Article 8 KPI calculations, source evidence, template ownership, and publication review before disclosures are finalized.

Primary sources

References and citations

eur-lex.europa.eu3 citations
Referenced sections
  • Current binding amendment for materiality options, revised financial-undertaking scope, simplified templates, and application timing.
  • Article 1 introduces separate 10% assessment thresholds for turnover, CapEx, and material OpEx, an OpEx non-materiality option, and separate reporting of omitted amounts.
  • Amends Article 7 denominator exclusions and the treatment of SPVs, voluntarily reporting counterparties, and known-use-of-proceeds exposures.
eur-lex.europa.eu3 citations
Referenced sections
  • Commission interpretation notice for Article 8 reporting of Taxonomy-eligible and Taxonomy-aligned economic activities and assets.
  • Commission interpretation notice with FAQ guidance on turnover, CapEx, OpEx, subcontracted activities, internal consumption, allocation, CapEx plans, and OpEx categories.
  • Clarifies use-of-proceeds sustainable bond treatment, adjusted KPIs, and double-counting issues for financial-undertaking GAR and GIR calculations.
"Taxonomy-eligible and Taxonomy-aligned"
More quoted passages
"FAQs ON TURNOVER KPI"
"avoid double counting"
eur-lex.europa.eu2 citations
Referenced sections
  • Disclosures Delegated Act specifying KPI content, presentation, methodologies, templates, and accompanying information under Article 8.
  • Disclosures Delegated Act specifying Article 8 content, presentation, methodologies, annexes, templates, and KPI routes for financial and non-financial undertakings.
"methodology to comply with that disclosure obligation"
More quoted passages
"content and presentation of information"
finance.ec.europa.eu2 citations
Referenced sections
  • Commission FAQ guidance on how financial and non-financial undertakings report Taxonomy-eligible activities and assets under the Article 8 Disclosures Delegated Act.
  • Commission FAQ guidance on Article 8 implementation and the treatment of voluntary information alongside mandatory Disclosures Delegated Act reporting.
"report Taxonomy-eligible economic activities"
More quoted passages
"should not be given more prominence"
eur-lex.europa.eu2 citations
Referenced sections
  • Primary Taxonomy Regulation source for Article 8 disclosure obligations and Article 3 conditions for environmentally sustainable economic activities.
  • Primary Taxonomy Regulation source for Article 8 disclosure duties and Article 3 criteria for environmentally sustainable economic activities.
"how and to what extent"
eur-lex.europa.eu
Referenced sections
  • Current Commission interpretation of Article 8 reporting after the 2026 amendments.
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