TaxonomyArticle 8 scopeEU

EU Taxonomy Article 8 Scope and reporting entities

Use this page to classify the reporting entity before choosing EU Taxonomy KPIs, templates, or evidence owners.

The scope test starts with Article 8 of Regulation (EU) 2020/852 and the Disclosures Delegated Act, not with a generic sustainability-reporting label.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 27, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
10

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 27, 2026
Overview

EU Taxonomy reporting scope is an entity-boundary decision. Article 8 applies to undertakings that must publish non-financial information under Articles 19a or 29a of Directive 2013/34/EU, and Commission Delegated Regulation (EU) 2021/2178 then separates the disclosures for non-financial undertakings, asset managers, credit institutions, investment firms, and insurance or reinsurance undertakings.

Section 1

Start with the Article 8 reporting trigger

The first question is whether the undertaking is subject to an obligation to publish non-financial information under Article 19a or Article 29a of Directive 2013/34/EU. Article 8 of Regulation (EU) 2020/852 attaches the Taxonomy disclosure obligation to that reporting population.

For an in-scope undertaking, the disclosure must explain how and to what extent its activities are associated with environmentally sustainable economic activities. The delegated act then defines the content, presentation, and methodology for the specific undertaking type.

  • Record whether the assessment is for an individual non-financial statement or a consolidated non-financial statement.
  • Keep the Article 19a or Article 29a basis in the scope memo; it is the legal gateway for Article 8 reporting.
  • Do not treat voluntary Taxonomy information as mandatory Article 8 disclosure unless the entity is actually in that reporting population.
Sources for this answer
Regulation (EU) 2020/852, Article 8
Article 8 links Taxonomy disclosures to undertakings required to publish non-financial information under Articles 19a or 29a of Directive 2013/34/EU.
Commission Delegated Regulation (EU) 2021/2178
The Disclosures Delegated Act specifies the content, presentation, and methodology for Article 8 disclosures.
Section 2

Classify the undertaking before choosing KPIs

The delegated act uses different disclosure routes for different reporting entities. A non-financial undertaking reports the Article 8 information specified in Annex I and presents it using Annex II templates. Financial undertakings follow entity-specific annexes instead.

The distinction matters because turnover, CapEx, and OpEx are the statutory KPIs for non-financial undertakings, while financial undertakings use KPIs designed for financing, investment, asset-management, investment-service, and insurance activities.

  • Non-financial undertaking: disclose Article 8 information under Annex I and Annex II.
  • Asset manager: use Annexes III and XI, presented through Annex IV.
  • Credit institution: use Annexes V and XI, presented through Annex VI; the green asset ratio is the central banking KPI.
  • Investment firm: use Annexes VII and XI, presented through Annex VIII.
  • Insurance or reinsurance undertaking: use Annexes IX and XI, presented through Annex X.
Sources for this answer
Commission Delegated Regulation (EU) 2021/2178, Articles 2-6
Articles 2 to 6 assign the applicable annexes and templates by undertaking type.
Commission Delegated Regulation (EU) 2021/2178, recitals
The recitals explain why financial undertakings need KPIs different from turnover, CapEx, and OpEx.
Section 3

Set the consolidation boundary before collecting data

The Commission Article 8 FAQ explains that undertakings preparing a non-financial statement under Article 19a, or a consolidated non-financial statement under Article 29a, should comply with Article 8 disclosure requirements. For consolidated reporting, the information is disclosed on a consolidated basis.

For mixed groups, the same FAQ states that the parent undertaking's classification controls the consolidated presentation: if the parent of the group is a financial company, the consolidated reporting is made as a financial undertaking. That decision should be made before teams request activity data from business units.

  • Document the parent entity and whether the report is individual or consolidated.
  • Identify mixed financial and non-financial lines before assigning templates.
  • Link the Taxonomy reporting boundary to the same consolidation principles used for the group's financial reporting.
  • Keep voluntary supplemental disclosures separate from mandatory Article 8 disclosures and explain their basis.
Sources for this answer
European Commission Article 8 FAQ, December 2021 updated January 2022
The FAQ addresses mixed groups and consolidated Article 8 reporting boundaries.
European Commission Article 8 FAQ, December 2021 updated January 2022
The FAQ says voluntary disclosures should not be treated as mandatory Article 8 disclosures and should be explained.
Section 4

Separate scope from eligibility and alignment

Being in Article 8 scope does not mean that an activity is Taxonomy-eligible or Taxonomy-aligned. The delegated act defines a Taxonomy-eligible economic activity as one described in the delegated acts adopted under the environmental-objective provisions of Regulation (EU) 2020/852, regardless of whether that activity meets the technical screening criteria.

That definition keeps the workflow in order: first confirm the reporting entity and undertaking type, then map activities to delegated acts, then test alignment criteria and calculate the applicable KPIs.

  • Scope decision: is this undertaking required to disclose under Article 8?
  • Entity decision: is it non-financial, an asset manager, a credit institution, an investment firm, or an insurance or reinsurance undertaking?
  • Eligibility decision: is the economic activity described in the relevant delegated act?
  • Alignment decision: does the activity meet the Taxonomy Regulation Article 3 conditions and related technical criteria?
Sources for this answer
Commission Delegated Regulation (EU) 2021/2178, Article 1
Article 1 defines Taxonomy-aligned, Taxonomy-eligible, Taxonomy-non-eligible, financial undertaking, and non-financial undertaking.
European Commission Article 8 FAQ, December 2021 updated January 2022
The FAQ explains that eligibility assessment is separate from accounting standards, while KPI calculation uses the relevant reporting methodology.
Section 5

Keep an evidence file for the reporting boundary

A useful scope file should let a reviewer trace the reporting obligation from the undertaking to the applicable Article 8 template. It should not be a generic EU Taxonomy policy note.

For each reporting cycle, keep the legal scope basis, undertaking type, consolidation conclusion, selected annexes, timing assumption, and any voluntary-disclosure explanation together with the financial-reporting sign-off.

  • Article 19a or Article 29a conclusion and the source used for it.
  • Entity classification: non-financial undertaking or named financial-undertaking category.
  • Consolidation basis and parent-entity classification for group reporting.
  • Applicable Article 8 annexes and templates.
  • KPI start date used for the reporting year, including any transition-period treatment.
  • Separate rationale for voluntary Taxonomy information, if included.
Sources for this answer
Commission Delegated Regulation (EU) 2021/2178, Article 10
Article 10 sets transition timing for non-financial undertakings, financial undertakings, and selected credit-institution KPIs.
Commission Delegated Regulation (EU) 2021/2178, Article 8
Article 8 requires additional disclosures accompanying KPIs to be included with the KPI disclosures or cross-referenced.
Recommended next step

Turn the Article 8 scope test into an evidence file

Use this EU Taxonomy scope guide to connect the reporting entity, undertaking type, applicable annexes, and evidence owners before KPI work begins.

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Primary sources

References and citations

Commission Delegated Regulation (EU) 2021/2178
eur-lex.europa.eu
Referenced sections
  • The Disclosures Delegated Act specifies the content, presentation, and methodology for Article 8 disclosures.
"undertakings subject to Articles 19a or 29a"
Regulation (EU) 2020/852, Article 8
eur-lex.europa.eu
Referenced sections
  • Article 8 links Taxonomy disclosures to undertakings required to publish non-financial information under Articles 19a or 29a of Directive 2013/34/EU.
"shall include in its non-financial statement"
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