EU Taxonomy + ESRS Integrated Modelling

Context

A large EU-listed industrial manufacturing group ("EuroManufacture AG") is subject to:

• CSRD
• ESRS
• EU Taxonomy Regulation (2020/852)
• Climate Delegated Act
• Environmental Delegated Act

The Regulatory Challenge

ESRS environmental disclosures and EU Taxonomy requirements overlap conceptually but differ structurally.

Without semantic separation:

• Climate data is duplicated across regimes
• DNSH documentation is managed through parallel spreadsheets
• CapEx taxonomy mapping becomes inconsistent
• Audit traceability fragments
• Regulatory drift risk increases

Canonical ESG is implemented as a structural modelling layer beneath both regimes.

Step 1 — Semantic Stabilisation (CDI Layer)

All sustainability and economic data is first mapped into CDI v1 prior to regulatory interpretation.

• CDI-CLIM-01 → Scope 1 Emissions
• CDI-CLIM-02 → Scope 2 Emissions
• CDI-CLIM-07 → Transition Plan
• CDI-BIOD-03 → Ecosystem Interaction
• CDI-MATR-04 → Circular Material Inputs
• CDI-GOVR-02 → Oversight of Sustainability Risks
• CDI-ECON-05 → Capital Allocation

• Single semantically stable dataset
• No embedded ESRS logic
• No embedded Taxonomy logic

Meaning is stabilised before interpretation.

Step 2 — ESRS Interpretation (CMP Layer)

Using ESRS topical CMPs and EU jurisdictional CMPs, CDIs are interpreted into reporting requirements.

• CDI-CLIM-01 → ESRS E1-6 GHG disclosure
• CDI-CLIM-07 → ESRS E1-1 Transition plan
• CDI-BIOD-03 → ESRS E4 Biodiversity impacts

Double materiality is layered at the interpretive level:

• Impact materiality
• Financial materiality

No new semantic fields are created. Interpretation is layered onto the stable baseline.

Step 3 — EU Taxonomy Regulatory Modelling

The same CDI dataset is interpreted through the EU Taxonomy CMP.

• Eligibility determination
• Alignment assessment
• Technical Screening Criteria
• DNSH tests
• Minimum safeguards

Example — Climate Mitigation Activity

Wind turbine gear manufacturing mapped to EU Taxonomy Activity 3.1.

• Eligible revenue: €1.2 billion (28.6%)
• Aligned turnover: €1.05 billion (25%)

DNSH and safeguards reuse existing CDI domains — no parallel spreadsheet structures are created.

EU Taxonomy Regulatory Layering Architecture

Figure — EU Taxonomy + ESRS Integrated Modelling Architecture

Step 4 — KPI Computation

• Aligned Turnover: 25%
• Aligned CapEx: 41%
• Aligned OpEx: 18%

KPIs are derived from the canonical economic base through layered interpretation.

Workflow Comparison (Illustrative)