Eligibility asks whether an economic activity is described in the Taxonomy delegated acts. Alignment asks whether that activity satisfies the Article 3 conditions for environmental sustainability.
This comparison helps keep scoping, KPI reporting, technical screening criteria, DNSH, and minimum-safeguards evidence separate.
and alignment are sequential but different conclusions. Eligibility asks whether an activity is described in a Taxonomy delegated act; it does not measure environmental performance. Alignment requires the activity to satisfy Article 3: substantial contribution to at least one environmental objective, no significant harm to the others, minimum safeguards, and the applicable technical screening criteria. For Article 8 reports prepared under the rules applicable from 1 January 2026, Commission Delegated Regulation (EU) 2026/73 also permits specified materiality-based omissions from eligibility and alignment assessment, with separate reporting of the omitted amounts.
Comparison matrix
Eligibility vs alignment: what each conclusion proves
Use the rows below to separate the scoping question from the sustainability-quality test that supports Article 8 disclosures.
An eligible economic activity is one described in the delegated acts adopted under the Taxonomy Regulation. Eligibility is a scope and reporting classification; it does not by itself prove that the activity is environmentally sustainable.
Second framework
Taxonomy alignment
A activity must meet the Article 3 conditions, including substantial contribution, DNSH, minimum safeguards, and the applicable technical screening criteria.
Eligibility vs alignment: what each conclusion proves
Do not present eligibility as proof of sustainability. Treat it as the entry point for KPI reporting and the starting population for alignment testing.
Undertakings subject to Article 8 use the KPI rules for their undertaking type. Non-financial undertakings report turnover, CapEx, and OpEx; asset managers, credit institutions, investment firms, and insurance or reinsurance undertakings use the applicable asset, revenue, or activity KPIs in the Disclosures Delegated Act.
Before including an amount as , the reporting undertaking must establish that the relevant activity satisfies the four Article 3 conditions. Financial undertaking KPIs may also depend on the Taxonomy information, use of proceeds, and reporting status of counterparties under the applicable methodology.
Assign eligibility mapping ownership and alignment evidence ownership to different teams or at least to different evidence folders so the two-step disclosure process can be audited separately.
An activity is eligible when it is described in a Taxonomy delegated act covering one of the six environmental objectives. Under the rules applicable from 1 January 2026, a non-financial undertaking may omit assessing activities whose cumulative turnover, CapEx, or material OpEx is below 10% of the denominator of the corresponding KPI. The omitted amount must be reported separately as non-material; the threshold does not make an activity eligible, aligned, or non-eligible.
Alignment is tested only for an eligible activity. The activity must meet the delegated-act substantial-contribution and DNSH criteria, comply with the Article 18 minimum safeguards, and satisfy the applicable technical screening criteria.
Keep the eligibility mapping and the alignment evidence chain in separate records so a future auditor can verify each step independently without conflating the scoping test with the sustainability test.
Eligibility reporting for a non-financial undertaking uses turnover, CapEx, and OpEx KPIs and the Disclosures Delegated Act templates. Amounts omitted under the 2026 materiality rules are reported separately as non-material rather than being classified as non-eligible. If OpEx is not material to the business model, the undertaking may omit assessing all OpEx activities only if it discloses the denominator and explains why OpEx is not material.
Alignment reporting obligations require additional evidence for substantial contribution, DNSH assessment, and minimum-safeguards compliance for each eligible activity reported as aligned, plus separate KPI tables for the aligned share.
Keep one evidence set for each obligation type: a delegated-act activity mapping for eligibility and a TSC, DNSH, and safeguards assessment for alignment, so neither set is confused with the other in disclosures.
Eligibility evidence should show the activity description used, the delegated act and objective consulted, and the mapping from revenue, CapEx, OpEx, asset, or exposure data to the reported KPI line.
Alignment evidence should add proof for substantial contribution, DNSH, minimum safeguards, and the applicable technical screening criteria for the activity and objective.
Eligibility was the first Article 8 reporting step: from January 2022, in-scope undertakings reported eligible and non-eligible activities or assets and qualitative information for the previous reporting period. Commission Delegated Regulation (EU) 2026/73 applies from 1 January 2026 and permits undertakings to use the rules in force on 31 December 2025 for a financial year beginning during 2025.
Alignment reporting followed later: non-financial undertakings reported aligned climate activities from 2023, and financial undertakings began the main eligible and aligned KPI reporting from 2024. The current report must use the delegated acts, criteria, templates, and transition option applicable to its financial year.
For historic or current reports, identify the financial year, undertaking type, environmental objective, KPI, and elected 2025 transition approach before deciding which assessment and template rules applied.
Article 8 disclosures sit in the management report of an undertaking subject to Articles 19a or 29a of the Accounting Directive. Where CSRD assurance requirements apply, the assurance opinion covers compliance with the sustainability-reporting requirements, including Article 8 reporting; national transposition determines the applicable statutory process.
The same reporting-level assurance scope covers alignment disclosures. That does not replace activity-level support for technical screening criteria, DNSH, minimum safeguards, and KPI calculations, or any independent verification expressly required by a particular screening criterion.
Keep the legal-scope analysis and assurance engagement separate from the activity evidence. Article 8 defines what is disclosed; the Accounting Directive and national law determine the reporting and assurance route.
Eligibility analysis produces activity descriptions and sector mappings that directly support the first step of alignment assessment and can be reused as the base layer for alignment evidence without repeating the delegated-act matching work.
Alignment evidence, such as technical screening criteria assessments, DNSH reviews, and safeguards checks, cannot be substituted for eligibility analysis even if alignment has been demonstrated, because the reporting templates require both KPIs to be disclosed separately.
Build the eligibility map first and use it as input to the alignment assessment; do not skip the eligibility step when alignment evidence is already available, as both disclosures are independently required.
Use the eligibility label only after mapping an activity to a delegated-act description and tying it to the relevant KPI denominator and reporting boundary.
In public copy, write 'eligible' and 'aligned' as separate conclusions. If an activity is eligible but lacks proof for one alignment condition, call it eligible but not aligned.
Do not present eligibility as proof of sustainability. Treat it as the entry point for KPI reporting and the starting population for alignment testing.
Undertakings subject to Article 8 use the KPI rules for their undertaking type. Non-financial undertakings report turnover, CapEx, and OpEx; asset managers, credit institutions, investment firms, and insurance or reinsurance undertakings use the applicable asset, revenue, or activity KPIs in the Disclosures Delegated Act.
Before including an amount as , the reporting undertaking must establish that the relevant activity satisfies the four Article 3 conditions. Financial undertaking KPIs may also depend on the Taxonomy information, use of proceeds, and reporting status of counterparties under the applicable methodology.
Assign eligibility mapping ownership and alignment evidence ownership to different teams or at least to different evidence folders so the two-step disclosure process can be audited separately.
An activity is eligible when it is described in a Taxonomy delegated act covering one of the six environmental objectives. Under the rules applicable from 1 January 2026, a non-financial undertaking may omit assessing activities whose cumulative turnover, CapEx, or material OpEx is below 10% of the denominator of the corresponding KPI. The omitted amount must be reported separately as non-material; the threshold does not make an activity eligible, aligned, or non-eligible.
Alignment is tested only for an eligible activity. The activity must meet the delegated-act substantial-contribution and DNSH criteria, comply with the Article 18 minimum safeguards, and satisfy the applicable technical screening criteria.
Keep the eligibility mapping and the alignment evidence chain in separate records so a future auditor can verify each step independently without conflating the scoping test with the sustainability test.
Eligibility reporting for a non-financial undertaking uses turnover, CapEx, and OpEx KPIs and the Disclosures Delegated Act templates. Amounts omitted under the 2026 materiality rules are reported separately as non-material rather than being classified as non-eligible. If OpEx is not material to the business model, the undertaking may omit assessing all OpEx activities only if it discloses the denominator and explains why OpEx is not material.
Alignment reporting obligations require additional evidence for substantial contribution, DNSH assessment, and minimum-safeguards compliance for each eligible activity reported as aligned, plus separate KPI tables for the aligned share.
Keep one evidence set for each obligation type: a delegated-act activity mapping for eligibility and a TSC, DNSH, and safeguards assessment for alignment, so neither set is confused with the other in disclosures.
Eligibility evidence should show the activity description used, the delegated act and objective consulted, and the mapping from revenue, CapEx, OpEx, asset, or exposure data to the reported KPI line.
Alignment evidence should add proof for substantial contribution, DNSH, minimum safeguards, and the applicable technical screening criteria for the activity and objective.
Eligibility was the first Article 8 reporting step: from January 2022, in-scope undertakings reported eligible and non-eligible activities or assets and qualitative information for the previous reporting period. Commission Delegated Regulation (EU) 2026/73 applies from 1 January 2026 and permits undertakings to use the rules in force on 31 December 2025 for a financial year beginning during 2025.
Alignment reporting followed later: non-financial undertakings reported aligned climate activities from 2023, and financial undertakings began the main eligible and aligned KPI reporting from 2024. The current report must use the delegated acts, criteria, templates, and transition option applicable to its financial year.
For historic or current reports, identify the financial year, undertaking type, environmental objective, KPI, and elected 2025 transition approach before deciding which assessment and template rules applied.
Article 8 disclosures sit in the management report of an undertaking subject to Articles 19a or 29a of the Accounting Directive. Where CSRD assurance requirements apply, the assurance opinion covers compliance with the sustainability-reporting requirements, including Article 8 reporting; national transposition determines the applicable statutory process.
The same reporting-level assurance scope covers alignment disclosures. That does not replace activity-level support for technical screening criteria, DNSH, minimum safeguards, and KPI calculations, or any independent verification expressly required by a particular screening criterion.
Keep the legal-scope analysis and assurance engagement separate from the activity evidence. Article 8 defines what is disclosed; the Accounting Directive and national law determine the reporting and assurance route.
Eligibility analysis produces activity descriptions and sector mappings that directly support the first step of alignment assessment and can be reused as the base layer for alignment evidence without repeating the delegated-act matching work.
Alignment evidence, such as technical screening criteria assessments, DNSH reviews, and safeguards checks, cannot be substituted for eligibility analysis even if alignment has been demonstrated, because the reporting templates require both KPIs to be disclosed separately.
Build the eligibility map first and use it as input to the alignment assessment; do not skip the eligibility step when alignment evidence is already available, as both disclosures are independently required.
Use the eligibility label only after mapping an activity to a delegated-act description and tying it to the relevant KPI denominator and reporting boundary.
In public copy, write 'eligible' and 'aligned' as separate conclusions. If an activity is eligible but lacks proof for one alignment condition, call it eligible but not aligned.
When should teams use this eligibility-vs-alignment explanation?
Use it before preparing Article 8 KPI tables, drafting sustainability-report language, reviewing green-finance claims, or deciding whether an activity can move from the eligible population into the aligned numerator.
The most common error is treating eligibility as an endorsement. It is not. Eligibility means the activity is covered by Taxonomy activity descriptions; alignment requires the separate environmental-sustainability test.
Use the eligibility review to map activities, reporting boundaries, and turnover, CapEx, OpEx, asset, investment, lending, or insurance data.
Use the alignment review to document technical screening criteria, substantial contribution, DNSH, and minimum safeguards.
Use separate labels for eligible, aligned, eligible but not aligned, and non-eligible activities in source records and public wording.
Explains that CSRD assurance rules apply to Article 8 disclosures to the same extent as other sustainability reporting once the CSRD requirements apply.
Articles 19a, 29a, and 34 establish the current sustainability-reporting and assurance framework that Article 8 Taxonomy disclosures enter through the management report.
Article 8 requires disclosure of how and to what extent activities are associated with environmentally sustainable activities; the Disclosures Delegated Act supplies the eligibility and alignment presentation rules.
Provides the core legal distinction between disclosure of activities associated with environmentally sustainable activities and the criteria for environmental sustainability.