EU TaxonomyRequirements

EU Taxonomy Regulation (EU) 2020/852 Requirements

Eligibility is not enough - alignment and evidence decide disclosure quality.

Use this as a requirements map for KPIs, delegated acts, and audit-ready evidence.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

EU Taxonomy requirements are easiest to implement as a chain: classify activities -> decide eligibility -> test alignment against technical screening criteria -> document DNSH + minimum safeguards -> compute and disclose Article 8 KPIs with traceable evidence. If any link is missing, the disclosure becomes fragile under assurance or stakeholder challenge.

Section 1

Alignment requirements: the four conditions you must satisfy

Taxonomy alignment is defined by four conditions: (1) substantial contribution to at least one environmental objective, (2) do no significant harm (DNSH) to the others, (3) compliance with minimum safeguards, and (4) compliance with technical screening criteria (TSC) set in delegated acts.

Operationally, this means you need an activity-level criteria mapping and evidence pack - not just a narrative.

Substantial contribution: meet the relevant TSC for the objective you claim
DNSH: meet DNSH criteria for the other objectives covered by that activity's criteria set
Minimum safeguards: responsible business conduct / human rights baseline is in place
TSC versioning: apply the criteria as defined for the reporting year and record the version

Recommended next step

Operationalize EU Taxonomy Regulation (EU) 2020/852 Requirements across ESG workflows

ESG Compliance can take EU Taxonomy Regulation (EU) 2020/852 Requirements from turning the requirements into assigned actions to a reusable workflow inside Sorena. Teams working on EU Taxonomy Regulation (EU) 2020/852 can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

ESG workflow

Open ESG Compliance for EU Taxonomy Regulation (EU) 2020/852 Requirements

Start from EU Taxonomy Regulation (EU) 2020/852 Requirements and manage cross team sustainability work, reporting, and evidence from one workflow.

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Section 2

Eligibility vs alignment: what you can claim and what you must prove

Eligibility is a coverage check: the activity matches a taxonomy activity definition in delegated acts. Alignment is a compliance claim: you meet all criteria and can substantiate it.

This distinction directly affects KPI numerators: only aligned activity components belong in aligned KPI numerators.

Eligibility register: activities mapped to accounts, sites, assets, and project boundaries
Alignment register: pass/fail per criterion with evidence pointers and owner
Non-alignment handling: a controlled way to keep eligible-but-not-aligned out of aligned KPI numerators
Change control: reassess when delegated acts expand/adjust criteria

Section 3

Disclosure requirements: Article 8 KPIs and accompanying information

The disclosures delegated act defines KPI templates, calculation rules, and phase-in dates. Non-financial undertakings disclose turnover/CapEx/OpEx proportions related to taxonomy-aligned activities. Financial undertakings disclose their own taxonomy KPIs (including GAR) that depend on counterparty data flows.

Treat KPI reporting as a recurring close process: a controlled workbook, reconciliations to audited numbers, and consistent methodological notes.

Non-financial KPIs: turnover KPI, CapEx KPI, OpEx KPI (aligned vs total)
Financial KPIs: GAR and other KPI templates; dependency on counterparty taxonomy KPIs
Accompanying information: narratives, methodology notes, estimates policy, and limitations
Audit trail: ability to reproduce KPI calculations and justify each numerator component

Section 4

Evidence and governance: what you need to make claims auditable

Evidence quality is traceability: KPI numerator -> activity -> criteria -> evidence -> owner -> timestamp. Without that chain, assurance cost and reporting risk both rise.

Define evidence packs per activity, and store them in a stable structure with a consistent index.

Criteria mapping file: criterion-by-criterion checklist with pass/fail and evidence links
DNSH evidence: assessments, permits, monitoring data, compliance attestations
Minimum safeguards evidence: due diligence processes, grievance mechanisms, remediation tracking
Controls: review gates and periodic refresh so evidence remains current

Primary sources