# 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.

<!--
Guidance: How to use this template
- Purpose: one auditable record behind the Taxonomy section of the
  sustainability statement. An assurance provider should be able to
  trace each number in the KPI tables to an activity, a criterion, a
  piece of evidence and the financial ledger.
- Work in this order: confirm the reporting basis (section 1), list and
  map activities (section 2), apply the materiality threshold (section
  3), test substantial contribution (section 4), DNSH (section 5) and
  minimum safeguards (section 6), then calculate KPIs (section 7) and
  write the narrative (section 8).
- Key changes from Delegated Regulation (EU) 2026/73, as summarised by
  the Commission and law firms (check the consolidated text): a 10%
  materiality threshold under which activities that in aggregate stay
  below 10% of turnover, CapEx or OpEx can be left out of the detailed
  eligibility and alignment assessment, applied per KPI; an exemption
  where OpEx is not material to the business model (report total OpEx
  and explain); simplified reporting templates with far fewer data
  points and no separate fossil gas and nuclear templates; and
  simplified generic DNSH criteria for pollution prevention and control
  (Appendix C). Undertakings could keep the previous rules for
  financial year 2025.
- The Omnibus I Directive (Directive (EU) 2026/470) narrowed the CSRD
  scope to more than 1,000 employees and over EUR 450 million net
  turnover. Article 8 disclosures follow the CSRD scope; confirm whether
  you are in scope or reporting voluntarily (section 1).
- The worked example uses the fictional Veltmark Building Systems SE
  (heat pumps, battery storage controllers, installation services;
  EUR, calendar year, FY2026). All names and figures are fictional.
- Related documents: Double Materiality Assessment
  (`finance/sustainability-double-materiality-assessment`), ISSB
  Sustainability Disclosure (`finance/issb-sustainability-disclosure`),
  CSDDD Due Diligence Plan (`finance/csddd-due-diligence-plan`), SFDR
  PAI Statement (`compliance/sfdr-pai-statement`), Responsible
  Investment Policy (`finance/responsible-investment-policy`), Capex
  Request (`finance/capex-request`) and Accounting Policy Manual
  (`finance/accounting-policy-manual`).
-->

## Document control

<!-- Guidance: One assessment per financial year. Record which version of the delegated acts you applied, because the FY2025 option and the simplification act make the version a disclosure point. -->

| Field | Value |
|---|---|
| Document ID | [TAX-YYYY] *Example:* TAX-2026 |
| Undertaking and consolidation scope | [Group, as in the financial statements] *Example:* Veltmark Building Systems SE and 9 subsidiaries |
| Financial year | [YYYY-01-01 to YYYY-12-31] *Example:* FY2026 |
| Reporting basis | [Mandatory under CSRD / voluntary] *Example:* Mandatory (more than 1,000 employees and over EUR 450 million turnover) |
| Delegated acts version applied | [As amended by (EU) 2026/73 / pre-amendment option] *Example:* As amended by (EU) 2026/73 |
| Currency and units | [EUR million] |
| Linked documents | [IDs] *Example:* DMA-2026, FS-2026 (consolidated financial statements) |
| Version | [0.1] |
| Status | [Draft / In review / Approved] |
| Owner | [@head-of-sustainability-reporting] |
| Approvers/reviewers | [@group-controller], [@cfo], [audit committee] |
| Last updated | YYYY-MM-DD |
| Classification | [Internal] |
| Assurance provider and level | [Firm, limited assurance] |

### Approvals

| Role | Name | Decision | Date |
|---|---|---|---|
| Preparer | [@name] | [Submitted] | YYYY-MM-DD |
| Group controller (ledger reconciliation) | [@name] | [Reconciled] | YYYY-MM-DD |
| Engineering lead (technical criteria) | [@name] | [Criteria evidence confirmed] | YYYY-MM-DD |
| CFO | [@name] | [Approved] | YYYY-MM-DD |
| Audit committee | [@chair] | [Noted] | YYYY-MM-DD |

### Revision history

| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | Activity inventory and mapping |
| 0.5 | YYYY-MM-DD | [@name] | *Example:* Criteria testing and KPI calculation |
| 1.0 | YYYY-MM-DD | [@name] | *Example:* Approved; tables handed to the reporting team |

## Contents

<!-- Guidance: Keep this list aligned with the headings. -->

1. [Reporting basis and scope](#1-reporting-basis-and-scope)
2. [Activity inventory and eligibility](#2-activity-inventory-and-eligibility)
3. [Materiality threshold](#3-materiality-threshold)
4. [Substantial contribution](#4-substantial-contribution)
5. [Do no significant harm](#5-do-no-significant-harm)
6. [Minimum safeguards](#6-minimum-safeguards)
7. [KPI calculation](#7-kpi-calculation)
8. [Contextual information and narrative](#8-contextual-information-and-narrative)
9. [Controls, evidence and assurance readiness](#9-controls-evidence-and-assurance-readiness)
10. [Glossary and references](#10-glossary-and-references)
11. [Standard and licence note](#11-standard-and-licence-note)

## 1. Reporting basis and scope

<!-- Guidance: Questions: Is the undertaking required to report under Article 8, or reporting voluntarily? Which version of the delegated acts applies to this year? Is the consolidation scope the same as in the financial statements? Pitfall: a Taxonomy perimeter that differs from the financial statements without a reconciliation. -->

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.

```mermaid
flowchart TD
  A["Economic activity"] --> B{"Described in a delegated act?"}
  B -- No --> N["Not eligible"]
  B -- Yes --> M{"Within 10% non-material aggregate?"}
  M -- "Yes, excluded" --> X["Reported as non-material, not assessed"]
  M -- No --> E["Eligible"]
  E --> C{"Meets substantial contribution criteria?"}
  C -- No --> EN["Eligible, not aligned"]
  C -- Yes --> D{"Meets all DNSH criteria?"}
  D -- No --> EN
  D -- Yes --> S{"Minimum safeguards met at entity level?"}
  S -- No --> EN
  S -- Yes --> AL["Aligned"]
```

## 2. Activity inventory and eligibility

<!-- Guidance: Start from revenue streams, capital projects and cost centres, then map each to an activity description in the Climate Delegated Act (EU) 2021/2139 or Environmental Delegated Act (EU) 2023/2486. Use the EU Taxonomy Compass to find the activity and its NACE codes. Questions: Does the activity description really match what you do, not only the NACE code? Pitfall: treating NACE codes as decisive; they are indicative only. -->

| Activity ID | Business line | Mapped activity (delegated act, section) | Objective | Type | Eligible? |
|---|---|---|---|---|---|
| ACT-01 *(Example)* | Heat pump manufacturing | Manufacture of energy efficiency equipment for buildings (Climate DA, Annex I, 3.5) | Mitigation | Enabling (check the Compass) | Yes |
| ACT-02 *(Example)* | Battery storage controllers | Manufacture of other low carbon technologies (Climate DA, Annex I, 3.6) | Mitigation | Enabling (check the Compass) | Yes |
| ACT-03 *(Example)* | Installation and service of heat pumps and insulation | Installation, maintenance and repair of energy efficiency equipment (Climate DA, Annex I, 7.3) | Mitigation | Check the Compass | Yes |
| ACT-04 *(Example)* | Solar thermal installation | Installation, maintenance and repair of renewable energy technologies (Climate DA, Annex I, 7.6) | Mitigation | Check the Compass | Yes |
| ACT-05 *(Example)* | Service fleet (vans) | Transport by motorbikes, passenger cars and light commercial vehicles (Climate DA, Annex I, 6.5) | Mitigation | Transitional or own performance (check) | Yes (CapEx only) |
| ACT-06 *(Example)* | Gas condensing boilers | No matching activity description | n/a | n/a | No |
| ACT-07 *(Example)* | Spare parts trading, other | No matching activity description | n/a | n/a | No |

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

<!-- Guidance: Delegated Regulation (EU) 2026/73 introduced a threshold under which activities that in aggregate account for less than 10% of a KPI may be treated as non-material and left out of the detailed assessment, tested separately for turnover, CapEx and OpEx. Questions: Which activities did you designate as non-material, and is their aggregate below 10% for that KPI? Did you choose to assess some anyway? Article 2(1a) to (1c) of the Disclosures Delegated Act as amended sets the test on the cumulative amount of the omitted activities against each KPI denominator, and Article 2(1d) asks for the omitted amounts to be reported separately as non-material. Pitfall: applying 10% per activity instead of in aggregate, or counting activities you assessed anyway. -->

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

| Candidate non-material activity | Turnover | Share | Cumulative share if omitted | Decision |
|---|---|---|---|---|
| ACT-04 Solar thermal installation *(Example)* | 38.0 | 3.1% | 3.1% | Could be omitted; assessed voluntarily because it is aligned |
| ACT-02 Battery storage controllers *(Example)* | 96.0 | 7.7% | 10.8% | Could be omitted on its own, but not together with ACT-04 (10.8% exceeds 10%); assessed anyway to show the gap to alignment |

*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):

| Candidate non-material activity | CapEx | Share | Cumulative share if omitted | Decision |
|---|---|---|---|---|
| ACT-03 Installation equipment *(Example)* | 6.0 | 4.1% | 4.1% | Assessed anyway (aligned) |
| ACT-05 Service fleet *(Example)* | 7.0 | 4.7% | 8.8% | Assessed anyway (partly aligned) |

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

<!-- Guidance: Test each eligible activity against its technical screening criteria in the delegated act. Questions: Which criterion applies, what evidence shows it is met, and for which share of the activity? Pitfall: claiming the whole activity aligned when only some products or projects meet the criteria; split the activity. -->

| Activity ID | Criterion (summarise in your own words; cite annex section) | Evidence | Result | Aligned share of turnover |
|---|---|---|---|---|
| ACT-01 *(Example)* | Heat pump models meet the product criteria referenced in section 3.5 (energy performance and refrigerant requirements; check section 4.16 cross-reference) | Model test certificates, refrigerant data sheets | Met for 11 of 14 model families | 548.0 of 612.0 |
| ACT-02 *(Example)* | Life-cycle greenhouse gas savings demonstrated and verified as required by section 3.6 | Life-cycle assessment not yet independently verified | Not met | 0.0 of 96.0 |
| ACT-03 *(Example)* | Installed measures are on the list of eligible individual measures in section 7.3 | Job records by measure type | Met except for boiler service jobs | 171.0 of 184.0 |
| ACT-04 *(Example)* | Installation of solar thermal systems as listed in section 7.6 | Job records | Met | 38.0 of 38.0 |
| ACT-05 *(Example)* | Vehicles meet the emission criteria in section 6.5 | Fleet register, type approval data | Met for battery-electric vans only | CapEx 4.2 of 7.0 |

## 5. Do no significant harm

<!-- Guidance: For each activity and each of the other five objectives, record the DNSH criterion and the evidence. The generic appendices of the Climate Delegated Act cover climate risk and vulnerability assessment (Appendix A), water (Appendix B), pollution and chemicals (Appendix C, simplified by the 2026 act) and biodiversity (Appendix D). Pitfall: a single group-level statement used as DNSH evidence for every site. -->

| Activity ID | Adaptation | Water | Circular economy | Pollution | Biodiversity | Result |
|---|---|---|---|---|---|---|
| ACT-01 *(Example)* | Physical climate risk assessment for both plants (Appendix A) | Not applicable to activity (check) | Design for durability, repairability and recycling documented | Substance screening under the amended Appendix C; refrigerant handling | Environmental impact assessment for plant expansion (Appendix D) | Met |
| ACT-03 *(Example)* | Risk assessment of installation operations | n/a | Waste management plan for removed equipment | Hazardous materials handling for insulation removal | n/a | Met |
| ACT-04 *(Example)* | Risk assessment | n/a | n/a | n/a | n/a | Met |
| ACT-05 *(Example)* | Risk assessment | n/a | Vehicle end-of-life and battery reuse or recycling | Tyre requirements in section 6.5 | n/a | Met for battery-electric vans |

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

<!-- Guidance: Article 18 requires procedures aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, including the ILO core conventions and the International Bill of Human Rights. The Platform on Sustainable Finance Final Report on Minimum Safeguards (October 2022) groups the test into four topics. Questions: Are there adequate due diligence processes, and are there final court rulings or other signs of failure in any topic? Pitfall: treating a code of conduct as sufficient without a working due diligence process. -->

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

| Topic | Process in place | Signals of failure checked | Evidence | Conclusion |
|---|---|---|---|---|
| Human rights, including labour and consumer rights *(Example)* | Human rights due diligence process (see `finance/csddd-due-diligence-plan`) | Court rulings, OECD National Contact Point cases, credible allegations | Policy, risk assessment, grievance log | Met |
| Bribery and corruption *(Example)* | Anti-bribery management system | Convictions, enforcement actions | `compliance/iso-37001-anti-bribery` | Met |
| Taxation *(Example)* | Tax strategy and governance | Breaches of tax law, non-cooperative jurisdictions | `finance/tax-strategy-statement` | Met |
| Fair competition *(Example)* | Competition law training and controls | Competition law fines | Training records | Met |

## 7. KPI calculation

<!-- Guidance: Calculate each KPI on the definitions in Annex I of the Disclosures Delegated Act as amended. Questions: Do the denominators reconcile to the financial statements? Is any amount counted twice across activities or objectives? Pitfall: using a different turnover figure from the income statement, or including CapEx for non-aligned parts of an activity in the numerator. -->

### 7.1 Turnover (EUR million, FY2026, fictional)

| Activity | Total | Eligible, aligned | Eligible, not aligned | Aligned share of KPI |
|---|---|---|---|---|
| ACT-01 Heat pump manufacturing (3.5) | 612.0 | 548.0 | 64.0 | 44.2% |
| ACT-02 Battery storage controllers (3.6) | 96.0 | 0.0 | 96.0 | 0.0% |
| ACT-03 Installation and service (7.3) | 184.0 | 171.0 | 13.0 | 13.8% |
| ACT-04 Solar thermal installation (7.6) | 38.0 | 38.0 | 0.0 | 3.1% |
| Eligible subtotal | 930.0 | 757.0 | 173.0 | 61.0% |
| Not eligible (ACT-06, ACT-07) | 310.0 | | | |
| Total turnover (reconciles to income statement) | 1,240.0 | | | |

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)

| Activity | Total | Aligned | Eligible, not aligned | Aligned share of KPI |
|---|---|---|---|---|
| ACT-01 (3.5) | 61.0 | 55.0 | 6.0 | 37.2% |
| ACT-02 (3.6) | 9.0 | 0.0 | 9.0 | 0.0% |
| ACT-03 (7.3) | 6.0 | 6.0 | 0.0 | 4.1% |
| ACT-05 (6.5) | 7.0 | 4.2 | 2.8 | 2.8% |
| Eligible subtotal | 83.0 | 65.2 | 17.8 | 44.1% |
| Not eligible | 65.0 | | | |
| Total CapEx (additions to PP&E, intangibles and right-of-use assets) | 148.0 | | | |

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

<!-- Guidance: The KPIs need a short explanation. Questions: What explains the year-on-year movement? Which judgements did you make (activity mapping, materiality exclusions, OpEx exemption)? Pitfall: a narrative that promises future alignment without a CapEx plan. -->

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

<!-- Guidance: Questions: Can each number be traced to a ledger extract and each criterion to a signed evidence file? Who reviewed it? Pitfall: engineering evidence held only by a project team and lost when the team changes. -->

| Control ID | Control | Frequency | Owner | Evidence |
|---|---|---|---|---|
| TC-01 *(Example)* | Activity mapping reviewed by finance and engineering | Annual | [@group-controller] | Signed mapping file |
| TC-02 *(Example)* | Turnover and CapEx extracts reconciled to the financial statements | Annual | [@group-controller] | Reconciliation workpaper |
| TC-03 *(Example)* | Product certificates checked for validity at year end | Annual | [@engineering-lead] | Certificate register |
| TC-04 *(Example)* | Minimum safeguards screening for allegations and rulings | Semi-annual | [@general-counsel] | Screening log |
| TC-05 *(Example)* | Materiality threshold calculation reviewed | Annual | [@head-of-sustainability-reporting] | Calculation in section 3 |

## 10. Glossary and references

<!-- Guidance: Define terms once and list the texts with version and date. -->

| Term | Meaning |
|---|---|
| Eligible | Activity described in a delegated act, whether or not it meets the criteria |
| Aligned | Eligible activity meeting substantial contribution, DNSH, minimum safeguards and technical screening criteria |
| DNSH | Do no significant harm to any other environmental objective |
| Enabling activity | Activity that directly enables other activities to contribute substantially (Article 16) |
| Transitional activity | Activity without a low-carbon alternative that meets specific criteria (Article 10(2)) |
| CapEx plan | Plan to expand an aligned activity or bring an eligible activity into alignment within a set period |

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.