EU Taxonomy · Regulation (EU) 2020/852 · Article 8

EU Taxonomy: from your activities to the Article 8 KPIs

Dcycle has an EU Taxonomy project that follows the regulation step by step: decide which activities are in the perimeter, enter the turnover, CapEx and OpEx denominators and lines, assess each activity against the official criteria of the Delegated Acts and get the Annex II templates of Regulation 2021/2178 ready to export to Excel. Your team and your experts make each verdict; Dcycle keeps the evidence and does the maths.

  • Activities from the official catalogue, with NACE codes
  • Validated denominators and numerator lines
  • Verbatim criteria, DNSH and minimum safeguards
  • Templates 1 and 2 of Annex II, exported to Excel

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What you are asked for

Who asks for the taxonomy and where it gets stuck

Three KPIs, but each one rests on decisions about activities, figures from the accounts and evidence for every criterion.

Assurance provider That every KPI can be traced back to the accounts and to the evidence for each technical criterion. Verdicts in one spreadsheet, evidence in emails and shared folders. Each verdict keeps its response and where the evidence is, and the Excel export can include the criteria evidence as an appendix.
Banks and investors How much of your turnover and CapEx is aligned, for green financing or their own GAR. The analysis was done once and nobody has updated it. The KPIs are computed from the project: change a line or a verdict and the report follows.
Finance The turnover, CapEx and OpEx denominators and their split by taxonomy activity. The accounts do not classify by activity and the split lives in a separate sheet. Denominators are entered row by row and validated; lines are assigned to approved activities, split where needed or imported from the Excel template.
Sustainability team Deciding which activities are in scope and which are not, with a reason. Reading hundreds of pages of Delegated Acts to find the right section. Activities come from the official catalogue, narrowed by NACE code; each one is approved or excluded with a reason the auditor can read.
Operations and technical teams Proof of each technical criterion: certificates, measurements, climate risk assessments. Nobody knows who owes which document, or by when. Each pending criterion becomes an action with an owner, a due date and the KPI it moves.
Legal and compliance The minimum safeguards: human rights, the OECD Guidelines, the ILO conventions. Assessed activity by activity, or not documented at all. Assessed once for the whole project, as Article 18 sets out, and applied to every activity.
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Product

The EU Taxonomy project, step by step, as the regulation asks

Perimeter and eligibility

Decide which activities count, with the official catalogue

Add your projects, pick their NACE codes and assign each one to an activity of the Climate and Environmental Delegated Acts. Each activity on the shortlist is pending, approved or excluded; excluding one asks for a reason, and only approved activities move on to Financials.

  • Official catalogue with the CELEX and annex of each activity
  • Enabling and transitional activities flagged
  • Exclusion with a category and an explanation for the auditor
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Turnover, CapEx and OpEx

Validated denominators, lines assigned to activities

Enter each denominator from your accounts, with intragroup eliminations and adjustments, and validate it. Then record each revenue stream and each CapEx and OpEx line, split the ones that cover several activities and see the eligible share before you close the figures.

  • Excel template to import the lines
  • OpEx marked as not material where Art. 2(1c) allows it
  • Checks before closing: 10% threshold, R&D double counting, eligible over the denominator
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Criteria and evidence

Each activity against the text of the act

For each approved activity you see the substantial contribution criteria and the do-no-significant-harm criteria for the other five objectives, quoted from the Delegated Act with their source. You choose the verdict, write how it is met and where the evidence is, and the outcome updates: aligned, partially aligned or not aligned.

  • Verbatim legal text with CELEX, annex and section
  • DNSH per objective, “N/A” where the act sets no criteria
  • Minimum safeguards assessed once for the project
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Article 8 report

The Annex II templates, computed from your figures and verdicts

Template 1 sums up each KPI: total, eligible, aligned and its split by objective, enabling and transitional. Template 2 breaks it down by activity. Nothing is re-keyed: change a line or a verdict and the report follows. You export it to Excel in English or Spanish, with the criteria evidence and the safeguards as appendices.

  • Templates 1 and 2 of Delegated Regulation 2021/2178
  • Provisional until Financials is closed and every criterion is decided
  • Excel export; the previous-year (N-1) columns stay empty for now
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What it is

What the EU Taxonomy is

The classification system set by Regulation (EU) 2020/852 that defines which economic activities count as environmentally sustainable.

EU Taxonomy in the glossary
  • 6

    environmental objectives

    Climate change mitigation and adaptation, water, circular economy, pollution and biodiversity.

  • 3

    KPIs to disclose

    The share of turnover, CapEx and OpEx linked to eligible and aligned activities.

  • 10%

    materiality threshold

    Activities that together stay below 10% of turnover, CapEx or OpEx can be left out of the assessment.

When an activity is aligned

Substantial contribution

It contributes substantially to at least one of the six environmental objectives.

Technical screening criteria

It meets the thresholds the delegated acts set for that activity, for example on emissions or energy efficiency.

Do no significant harm (DNSH)

It does not significantly harm any of the other five objectives.

Minimum safeguards

The company follows the OECD Guidelines, the UN Guiding Principles and the ILO core conventions.

Where the criteria for each objective sit

Environmental objectiveDelegated act
Climate change mitigationClimate Delegated Act (2021/2139)
Climate change adaptationClimate Delegated Act (2021/2139)
Sustainable use and protection of water and marine resourcesEnvironmental Delegated Act (2023/2486)
Transition to a circular economyEnvironmental Delegated Act (2023/2486)
Pollution prevention and controlEnvironmental Delegated Act (2023/2486)
Protection and restoration of biodiversity and ecosystemsEnvironmental Delegated Act (2023/2486)
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How it works

Eligible is not the same as aligned

An activity is eligible if the delegated acts describe it. It is aligned only if it also meets all four conditions.

  1. 1Identify your eligible activitiesMatch what your company does against the activity descriptions in the delegated acts and set aside those that are not material.
  2. 2Check substantial contributionFor each eligible activity, review the technical criteria of the objective it contributes to, with its data and evidence.
  3. 3Review DNSHCheck that the activity does not harm the other five objectives: climate risks, water, waste, pollution and biodiversity.
  4. 4Verify the minimum safeguardsDocument your due diligence processes on human rights, anti-corruption, taxation and fair competition.
  5. 5Calculate and disclose the KPIsSplit turnover, CapEx and OpEx into aligned, eligible but not aligned and not eligible, and disclose them in the sustainability statement templates.
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Omnibus I

What the simplification changed in the taxonomy

Directive (EU) 2026/470 (Omnibus I) narrows who reports, and the taxonomy simplification delegated act, applicable since 1 January 2026, cuts how much.

TopicBeforeNow
Who discloses the KPIsCompanies in the original CSRD scope (from 250 employees)Companies with more than 1,000 employees and more than €450 million turnover
Activities to assessEvery eligible activityOnly material ones: those that together stay below 10% of turnover, CapEx or OpEx can be left out
OpEx KPIMandatory for everyoneExempt if OpEx is not material to your business model
Reporting templatesExtensive Disclosures Delegated Act templatesSimplified templates with far fewer datapoints
Pollution DNSHGeneral criterion on chemicalsSimplified criterion
Wave 1 companies now out of scopeReporting since financial year 2024May be exempt for 2025 and 2026, depending on each Member State’s transposition
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Why Dcycle

The taxonomy in spreadsheets or in Dcycle

What changes when activities, figures, criteria and evidence live in one project.

Spreadsheets and emailWith Dcycle
Eligible activitiesSearched by hand in the Delegated ActsOfficial catalogue narrowed by NACE code
DenominatorsCopied from the accounts with no checkEntered row by row and validated
Technical criteriaSummarised in a spreadsheetThe act’s own text next to each verdict
EvidenceIn emails and shared foldersRecorded with each verdict, open items as actions
KPIsRecalculated by hand after every changeComputed from lines and verdicts
ReportAnnex II templates built by handTemplates 1 and 2 exported to Excel
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FAQ

EU Taxonomy frequently asked questions

Which companies have to report under the EU Taxonomy?

Article 8 of the Taxonomy Regulation applies to companies that must publish a CSRD sustainability statement. After Omnibus I, that means companies with more than 1,000 employees and more than €450 million turnover. Member States have until 19 March 2027 to transpose it, and wave 1 companies that fall below the thresholds may be exempt for 2025 and 2026.

What is the difference between an eligible and an aligned activity?

An activity is eligible when it is described in the taxonomy delegated acts. It is aligned when it also contributes substantially to an environmental objective by meeting its technical criteria, does no significant harm to the other five objectives (DNSH) and the company meets the minimum safeguards. Both shares are disclosed.

Which KPIs are disclosed, and where?

The share of turnover, CapEx and OpEx associated with aligned, eligible but not aligned, and not eligible activities. They are disclosed in the sustainability statement of the management report, within the environmental information, using the Disclosures Delegated Act templates.

What does the 10% materiality threshold mean?

Under the simplification applicable since 1 January 2026, non-financial companies do not have to assess the eligibility or alignment of activities that together account for less than 10% of their turnover, CapEx or OpEx. They can also skip the OpEx KPI when OpEx is not material to their business model.

Does Dcycle calculate taxonomy alignment automatically?

Dcycle computes the KPIs, but it does not decide for you. From your validated denominators, the numerator lines you assign to approved activities and the verdict on each criterion, it calculates the eligible and aligned share of turnover, CapEx and OpEx and fills Templates 1 and 2 of Annex II. Whether an activity meets its substantial contribution and DNSH criteria is decided by your team and your experts, with the text of the act in front of them; Dcycle records each verdict with its response and evidence. The report is exported to Excel.

Why am I asked for taxonomy data if I am not obliged to report?

Because banks calculate their green asset ratio (GAR) from their clients’ information and asset managers need it for SFDR. Green loans and green bonds also tend to require proof of how much of the investment is aligned.

What evidence does the assurance provider usually ask for?

The accounting support for the denominators and for the split of turnover, CapEx and OpEx by activity, and proof of each technical criterion: energy performance certificates, emissions measurements, equipment data sheets, climate risk assessments and the policies covering the minimum safeguards. In Dcycle each verdict keeps its response and the reference to its evidence, and the Excel export can include them as an appendix.

Does the taxonomy apply if my company is outside the EU?

Non-EU groups fall into scope through the CSRD rules for third-country companies: more than €450 million net turnover in the EU, with a subsidiary or branch above €200 million. The taxonomy disclosure then goes in the sustainability report covering the EU business.

Talk to our team

We work out with you how to prepare your EU Taxonomy reporting

In 30 minutes we look at your case: whether it applies after Omnibus I, which activities may be eligible and how your figures and evidence would go through the EU Taxonomy project up to the Article 8 report.

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  • No commitment
  • Data hosted in Europe (GDPR)