EU Taxonomy Alignment Assessment Template (Article 8 KPIs)

EU Taxonomy Alignment Assessment: [Undertaking or group name] [Financial year]

A working file that records how a non-financial undertaking identified its Taxonomy-eligible economic activities, tested them against the technical screening criteria (substantial contribution and "do no significant harm", DNSH), checked minimum safeguards, and calculated the turnover, capital expenditure (CapEx) and operating expenditure (OpEx) key performance indicators (KPIs) for disclosure. Based on the Taxonomy Regulation (Regulation (EU) 2020/852), Article 8, the Disclosures Delegated Act (Commission Delegated Regulation (EU) 2021/2178), the Climate Delegated Act (EU) 2021/2139 and the Environmental Delegated Act (EU) 2023/2486, all as amended by Commission Delegated Regulation (EU) 2026/73 (the Taxonomy simplification act, OJ 2026-01-08, applying from 2026-01-01). Articles and annex sections are cited by number; obtain the consolidated texts on EUR-Lex. Replace every [bracketed] value and every row marked Example. This is a document format, not legal, accounting, audit or financial advice; check the current official text and a qualified professional.

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Contents

1. Reporting basis and scope
2. Activity inventory and eligibility
3. Materiality threshold
4. Substantial contribution
5. Do no significant harm
6. Minimum safeguards
7. KPI calculation
8. Contextual information and narrative
9. Controls, evidence and assurance readiness
10. Glossary and references
11. Standard and licence note

1. Reporting basis and scope

Record the basis in one paragraph. Example: "Veltmark Building Systems SE reports under Article 8 of Regulation (EU) 2020/852 as part of its sustainability statement for FY2026. It applies Delegated Regulation (EU) 2021/2178 and the Climate and Environmental Delegated Acts as amended by Delegated Regulation (EU) 2026/73. The consolidation scope equals that of the IFRS consolidated financial statements."

The Taxonomy assesses an activity as environmentally sustainable (aligned) when it meets all four conditions in Article 3 of Regulation (EU) 2020/852:

1. It contributes substantially to one or more of the six environmental objectives in Article 9 (climate change mitigation, climate change adaptation, water and marine resources, circular economy, pollution prevention and control, biodiversity and ecosystems).
2. It does no significant harm to any of the other objectives (Article 17).
3. It is carried out in compliance with the minimum safeguards (Article 18).
4. It complies with the technical screening criteria in the delegated acts.

2. Activity inventory and eligibility

Record for each eligible activity the evidence used to decide the match (product data sheets, contracts, project lists). Where an activity could contribute to more than one objective, record the objective you assess against and avoid double counting in the KPIs.

3. Materiality threshold

Turnover test (EUR million, total turnover 1,240.0):

Example result: no turnover is omitted, so non-material turnover is reported as EUR 0.0 million.

CapEx test (EUR million, total CapEx 148.0):

OpEx: the Taxonomy OpEx denominator (research and development, building renovation, short-term leases, maintenance and repair, and other direct servicing costs) is EUR 31.0 million against total operating costs of EUR 1,050 million (3.0%). Example decision: OpEx is not material to the business model; Veltmark applies the OpEx exemption, reports total Taxonomy OpEx and explains why (section 8).

4. Substantial contribution

5. Do no significant harm

For each "Met", reference the evidence file (section 9). For each "Not applicable", record why the delegated act sets no criterion for that objective for this activity.

6. Minimum safeguards

Minimum safeguards are assessed at the level of the undertaking. If they are not met, no activity can be reported as aligned.

7. KPI calculation

7.1 Turnover (EUR million, FY2026, fictional)

Turnover KPIs: eligible 75.0%, aligned 61.0%, eligible but not aligned 14.0%, not eligible 25.0%.

7.2 CapEx (EUR million, FY2026, fictional)

CapEx KPIs: eligible 56.1%, aligned 44.1%, not eligible 43.9%. Record whether any aligned CapEx relies on a CapEx plan to upgrade an activity to alignment, and attach the plan with its approval date and timeline.

7.3 OpEx

Example: OpEx exemption applied (section 3). Total Taxonomy OpEx EUR 31.0 million reported; no eligibility or alignment split.

7.4 Reconciliation and double counting checks

• Turnover denominator equals revenue in the consolidated income statement.
• CapEx denominator equals additions in the PP&E, intangible asset and right-of-use asset notes, before depreciation and remeasurement.
• Each amount is allocated to one activity and one objective only.
• Intragroup transactions are eliminated.

8. Contextual information and narrative

Write the narrative for the sustainability statement covering:

• Accounting policy for each KPI and the link to the financial statements.
• Activities designated as non-material and the aggregate share per KPI.
• Use of the OpEx exemption and why OpEx is not material to the business model.
• Main judgements: activity mapping, splits within activities, treatment of products partly meeting criteria.
• Year-on-year change and its drivers. Example: "The aligned turnover share rose from 54.8% to 61.0% because three new heat pump model families met the criteria."
• Plans to bring eligible activities into alignment. Example: "Independent verification of the life-cycle assessment for battery storage controllers is planned for 2027."

9. Controls, evidence and assurance readiness

10. Glossary and references

References:

• Regulation (EU) 2020/852 (Taxonomy Regulation), Articles 3, 8, 9, 10, 16, 17 and 18. EUR-Lex: https://eur-lex.europa.eu/eli/reg/2020/852/oj
• Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act), Annexes I and II. EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj
• Commission Delegated Regulation (EU) 2021/2139 (Climate Delegated Act) and (EU) 2023/2486 (Environmental Delegated Act). EUR-Lex.
• Commission Delegated Regulation (EU) 2026/73 amending the three acts above, adopted 2025-07-04, OJ 2026-01-08, applying from 2026-01-01. EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2026/73/oj
• Directive (EU) 2026/470 (Omnibus I) on CSRD scope. EUR-Lex.
• European Commission, EU taxonomy for sustainable activities (page with draft FAQ notice of December 2025 on the amended Disclosures Delegated Act): https://finance.ec.europa.eu/sustainable-finance/tools-and-standards/eu-taxonomy-sustainable-activities_en
• EU Taxonomy Navigator (Compass, calculator, FAQ repository): https://ec.europa.eu/sustainable-finance-taxonomy/
• Platform on Sustainable Finance, Final Report on Minimum Safeguards, October 2022 (name only).

11. Standard and licence note

Based on Regulation (EU) 2020/852 and Commission Delegated Regulations (EU) 2021/2178, 2021/2139 and 2023/2486 as amended by Commission Delegated Regulation (EU) 2026/73. Articles and annex sections are cited by number and criteria are summarised in original words; no legislative text is reproduced. The structure, guidance, controls and the Veltmark Building Systems example are original; Veltmark and every figure are fictional. The Commission was reviewing the technical screening criteria and the reporting KPIs in 2026; check the consolidated texts on EUR-Lex, the Commission FAQ and the Taxonomy Compass before use. This is a document format, not legal, accounting, audit or financial advice; consult a qualified professional.

Template licence: MIT.