| Question answered | Eligibility answers: is this economic activity described in a Taxonomy delegated act for one of the environmental objectives? | Alignment answers: does the eligible activity also qualify as environmentally sustainable under Article 3 and the relevant delegated-act criteria? | Do not present eligibility as proof of sustainability. Treat it as the entry point for KPI reporting and the starting population for alignment testing. |
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| Who must act | Undertakings subject to Article 8 disclosure obligations under the NFRD or CSRD must report the proportion of Taxonomy-eligible economic activities in their turnover, CapEx, and OpEx using the Disclosures Delegated Act templates. | The same undertakings must additionally demonstrate that eligible activities satisfy the four Article 3 alignment conditions before reporting them as Taxonomy-aligned in the KPI templates. | 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. |
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| Trigger or threshold | Eligibility is triggered when an economic activity is described in a Taxonomy delegated act covering any of the six environmental objectives. No quantitative threshold is needed; the match to the delegated-act activity description is sufficient to report the activity as eligible. | Alignment is triggered only after eligibility is confirmed. It requires meeting the substantial contribution criteria, the DNSH requirements for all other objectives, and the minimum social safeguards set out in the applicable delegated-act 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. |
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| Core obligations | Eligibility reporting obligations require calculating the share of eligible turnover, CapEx, and OpEx against total figures using the Disclosures Delegated Act templates, and disclosing what proportion of business is not covered by any Taxonomy delegated act. | 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. |
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| Evidence needed | 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 evidence can feed the alignment file, but it is incomplete unless the alignment criteria are documented and retained. |
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| Reporting timing | Eligibility was the first Article 8 reporting step: from January 2022, large undertakings reported eligible and non-eligible activities and qualitative information for the previous reporting period. | Alignment reporting followed later: large non-financial undertakings reported aligned climate activities in 2023, and large financial institutions reported eligible and aligned climate activities in 2024. | When reviewing historic reports, check which reporting year and undertaking type applied before judging whether an alignment assessment should have been present. |
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| Enforcement and assurance | Eligibility disclosures are included in the NFRD or CSRD non-financial or sustainability statements and are subject to the statutory audit or limited assurance review applicable to those reports under national audit and accounting frameworks. | Alignment disclosures are subject to the same audit or assurance scope. The technical screening criteria, DNSH conditions, and minimum-safeguards evidence should be maintained so an assurance provider or supervisor can verify the alignment calculation independently. | Keep source evidence for each activity at a level of detail that satisfies audit or assurance review, because eligibility and alignment disclosures now fall within the statutory and supervisory scope of CSRD assurance frameworks. |
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| Overlap and reuse | 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. |
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| Practical decision rule | 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. | Use the aligned label only after the same activity passes all Article 3 conditions and the evidence is strong enough for Article 8 presentation. | 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. |
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