EU Taxonomy Article 8 Disclosure templates

Start with a template selector before anyone builds a workbook. Article 8 applies to undertakings covered by Article 19a or 29a sustainability reporting, while the Disclosures Delegated Act separates the presentation route by undertaking type. Regulation (EU) 2026/73 replaced the annex templates with shorter versions from 1 January 2026.

Non-financial undertakings disclose the information specified in Annex I and present it using the Annex II templates. Asset managers use Annexes III and XI and the Annex IV template; credit institutions use Annexes V and XI and the Annex VI template; investment firms use Annexes VII and XI and the Annex VIII template; insurance and reinsurance undertakings use Annexes IX and XI and the Annex X templates.

Create one activity record before calculating any KPI numerator. The Disclosures Delegated Act defines a Taxonomy-eligible activity as an activity described in the delegated acts, irrespective of whether it meets the technical screening criteria. That means the template should first prove the activity is described in an applicable delegated act, then separately assess alignment.

The Commission FAQ warns that value-chain assumptions can be wrong: a supplier to a Taxonomy-eligible activity is not automatically Taxonomy-eligible for turnover reporting, and purchasing the output of a Taxonomy-eligible activity is not automatically eligible unless it fits the relevant CapEx or OpEx category.

For non-financial undertakings, the workbook should keep three controlled calculation tabs: turnover, CapEx, and OpEx. Article 8(2) names those KPIs, and Annex I of the Disclosures Delegated Act sets their methodology and accompanying disclosure requirements.

Do not let the Annex II table be the only working file. The table is the presentation layer; the working template should retain line-item source data, numerator decisions, denominator references, environmental-objective breakdowns, double-counting checks, and contextual notes.

Eligibility is not enough for an aligned KPI. The Taxonomy Regulation requires an environmentally sustainable activity to contribute substantially to one or more environmental objectives, do no significant harm to the other objectives, comply with minimum safeguards, and satisfy technical screening criteria.

Use a separate evidence pack for each aligned activity or financed activity. The pack should be narrow enough for review: it should show the exact criterion, evidence item, source system, date, reviewer, and open issue rather than a broad sustainability narrative.

Financial undertaking templates need counterparty and exposure controls that are not visible in the final percentage alone. Credit institution GAR, asset manager investment KPIs, investment firm KPIs, and insurance or reinsurance KPIs depend on the undertaking type, applicable annex, exposure category, counterparty KPI, and exclusions.

Under the rules applying from 1 January 2026, Article 7 excludes derivatives, cash and cash equivalents, on-demand interbank loans, goodwill, commodities, and other assets outside Article 7(6) from financial-undertaking KPI denominators. Exposures to undertakings outside Articles 19a or 29a and outside groups covered by those provisions are also excluded, subject to specific SPV, voluntary-reporting, and known-use-of-proceeds exceptions.

The final checklist should compare the public Article 8 disclosure against the calculation workbooks, annex templates, and evidence packs. Article 8 of the Disclosures Delegated Act requires accompanying disclosures to appear in the same parts of the non-financial statement as the KPIs or through cross-references to those parts.

The checklist should also prevent stale or overstated voluntary material. Commission FAQ guidance says voluntary information should not contradict or misrepresent mandatory disclosures, should not be more prominent than mandatory disclosures, and should explain its basis and methods.