EU Taxonomy Article 8 Scope and reporting entities

The first question is whether the undertaking must publish sustainability information under Article 19a or Article 29a of Directive 2013/34/EU for the reporting year. Article 8 of Regulation (EU) 2020/852 attaches the Taxonomy disclosure obligation to that reporting population. Determine that Accounting Directive status under the rules applicable to the undertaking; the Taxonomy Regulation does not create a separate size test.

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.

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.

An undertaking reporting under Article 19a prepares Taxonomy information for its individual reporting boundary. A parent reporting under Article 29a includes the group subsidiaries in consolidated Taxonomy disclosures, including subsidiaries that use a group-reporting exemption or are not individually subject to Articles 19a or 29a.

Mixed groups need more than a single parent label. Current Commission guidance says a reporting parent with financial and non-financial business segments should report the relevant consolidated KPIs for each financial segment and consolidated turnover and CapEx KPIs for non-financial activities, using the prescribed weighting approach. Record the prudential consolidation used for regulated financial activities and the Accounting Directive group boundary used for consolidated sustainability reporting.

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.

Commission Delegated Regulation (EU) 2026/73 applies from 1 January 2026. For a financial year starting during 2025, an undertaking may instead use the Taxonomy rules as they stood on 31 December 2025. The scope memo should record which rule set was chosen because the amended act changes materiality options, templates, and financial-undertaking denominators.

The amendment lets non-financial undertakings omit eligibility and alignment assessment for activities whose cumulative turnover or CapEx is below 10% of the corresponding KPI denominator, with separate reporting as non-material. It also gives financial undertakings that make no Taxonomy association claim a temporary standardized-statement route until 31 December 2027. Neither option removes the underlying Article 8(1) disclosure duty.

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.