Regulations

EU Taxonomy

The EU Taxonomy is a classification system that defines which economic activities are environmentally sustainable, guiding investment, reporting, and capital allocation.

Investors, lenders, and funds increasingly use the EU Taxonomy to screen investments, allocate capital, and define sustainable portfolios.

Defines what qualifies as environmentally sustainable activity

Used in CSRD reporting and sustainable finance

Impacts investment decisions and capital flows

Links ESG directly to financial classification and disclosure

EU Taxonomy in 30 Seconds

The EU Taxonomy is a classification system for sustainable economic activities

It defines criteria for environmental sustainability

Companies must disclose taxonomy-aligned activities under CSRD

Used by investors to assess sustainability

Applies across sectors and industries

EU Taxonomy determines what counts as "sustainable" in financial and regulatory terms

What the EU Taxonomy Actually Does

The EU Taxonomy provides a standardized framework for classifying sustainable economic activities.

Classifies Economic Activities

Determines whether an activity is sustainable

Defines Technical Criteria

Specific thresholds and conditions

Enables Comparability

Standardized definition across companies

Links to Disclosure

Companies must report taxonomy alignment

EU Taxonomy converts sustainability into a measurable and comparable classification system

The taxonomy does not mandate activities—it defines how they are classified and evaluated

The Six Environmental Objectives

An activity must contribute to at least one of six objectives to be considered taxonomy-aligned.

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution prevention

Biodiversity and ecosystems

These objectives define the scope of environmental sustainability

Detailed Environmental Objectives

Each environmental objective has specific criteria and requirements for substantial contribution. Climate change mitigation and adaptation have the most developed technical screening criteria, with other objectives progressively implemented.

1. Climate Change Mitigation

Activities that substantially contribute to stabilizing greenhouse gas concentrations in the atmosphere:

  • Renewable energy generation: Solar, wind, hydro, geothermal, biomass
  • Energy efficiency: Building renovation, efficient equipment, industrial processes
  • Low-carbon transport: Electric vehicles, rail, public transport infrastructure
  • Carbon capture and storage: CCS technologies and infrastructure
  • Manufacturing of low-carbon technologies: Batteries, renewable energy equipment

2. Climate Change Adaptation

Activities that increase resilience to climate change impacts:

  • Flood protection: Flood defenses, drainage systems, natural water retention
  • Heat adaptation: Cooling systems, green infrastructure, urban planning
  • Drought resilience: Water efficiency, irrigation systems, drought-resistant crops
  • Infrastructure resilience: Strengthening buildings, transport, energy systems
  • Ecosystem-based adaptation: Restoration of mangroves, wetlands, forests

3. Water and Marine Resources

Activities that protect and improve water quality and marine ecosystems:

  • Water treatment: Wastewater treatment, water recycling, desalination
  • Water efficiency: Water-saving technologies, leak detection, efficient irrigation
  • Marine protection: Sustainable fishing, marine habitat restoration, pollution control
  • Ecosystem services: Wetland protection, river restoration, biodiversity conservation

4. Circular Economy

Activities that promote circularity and resource efficiency:

  • Recycling and recovery: Material recycling facilities, waste-to-energy, composting
  • Product design: Durable, repairable, recyclable product design
  • Remanufacturing: Refurbishment, remanufacturing, reuse of components
  • Sharing platforms: Product-as-a-service, sharing economy models
  • Bio-based materials: Bio-based products, biodegradable materials

5. Pollution Prevention

Activities that prevent or reduce pollution of air, water, and soil:

  • Air pollution control: Emission reduction technologies, monitoring systems
  • Water pollution prevention: Industrial wastewater treatment, agricultural runoff control
  • Soil protection: Contaminated site remediation, soil conservation
  • Chemical management: Safer chemicals, pollution prevention planning
  • Noise and vibration control: Noise reduction technologies, urban planning

6. Biodiversity and Ecosystems

Activities that protect and restore biodiversity and ecosystems:

  • Habitat restoration: Reforestation, wetland restoration, habitat creation
  • Species conservation: Species protection programs, wildlife corridors
  • Sustainable forestry: Sustainable forest management, agroforestry
  • Sustainable agriculture: Organic farming, regenerative agriculture, biodiversity-friendly practices
  • Ecosystem services: Pollination, soil health, water regulation services

Climate Objectives Have Priority

Climate change mitigation and adaptation objectives have the most developed technical screening criteria and are the primary focus for initial taxonomy implementation. Other objectives are being progressively developed with sector-specific criteria.

Core Criteria (How It Works)

To be taxonomy-aligned, an activity must meet four criteria simultaneously.

1

Substantially Contribute - To at least one environmental objective

2

Do No Significant Harm (DNSH) - Not harm other objectives

3

Meet Minimum Safeguards - Social and governance standards

4

Meet Technical Screening Criteria - Quantitative thresholds

All four criteria must be met simultaneously

Failing any one of the criteria means the activity is not considered taxonomy-aligned

Technical Screening Criteria

Technical screening criteria (TSC) are the quantitative and qualitative thresholds that determine whether an activity substantially contributes to an environmental objective. TSC are defined at the activity level and vary by sector and objective.

Activity-Level Criteria

TSC are defined for specific economic activities (NACE codes). Each activity has specific criteria depending on which environmental objective it contributes to. For example, renewable energy generation has specific capacity and efficiency thresholds, while building renovation has specific energy performance requirements.

Substantial Contribution Criteria

Activities can substantially contribute through three pathways:

  • Transition activities: Activities that enable the transition to a sustainable economy (e.g., manufacturing low-carbon technologies)
  • Enabling activities: Activities that directly enable other sustainable activities (e.g., manufacturing renewable energy equipment)
  • Green activities: Activities that are already environmentally sustainable (e.g., renewable energy generation)

Quantitative Thresholds

TSC include specific quantitative thresholds such as:

  • Emission thresholds: Maximum GHG emissions per unit of output (e.g., gCO2e/kWh for electricity)
  • Efficiency thresholds: Minimum energy efficiency or resource efficiency standards
  • Recycling thresholds: Minimum recycled content or recovery rates
  • Performance thresholds: Minimum environmental performance indicators

Sector-Specific Delegated Acts

TSC are published through delegated acts for specific sectors. Climate-related delegated acts (mitigation and adaptation) cover activities in sectors such as energy, manufacturing, transport, buildings, agriculture, and forestry. Delegated acts for other environmental objectives are being progressively developed.

TSC Are Activity-Specific

Technical screening criteria are defined at the activity level, not the company level. A company may have multiple activities, some aligned and some not, depending on whether each activity meets its specific TSC.

DNSH & Minimum Safeguards

Beyond substantial contribution, taxonomy-aligned activities must satisfy Do No Significant Harm (DNSH) requirements and minimum safeguards for social and governance standards.

Do No Significant Harm (DNSH)

An activity that substantially contributes to one environmental objective must not significantly harm any of the other five objectives:

  • Climate mitigation activities must not harm climate adaptation, water, circular economy, pollution, or biodiversity
  • Renewable energy projects must not cause significant harm to biodiversity (e.g., avoid protected areas)
  • Industrial processes must not cause significant water pollution or resource depletion
  • DNSH assessment requires evaluation of potential impacts on all other objectives

DNSH Evidence Requirements

Companies must provide evidence that activities meet DNSH requirements:

  • Screening: Identify potential significant harm to other objectives
  • Assessment: Evaluate the significance of potential impacts
  • Mitigation: Implement measures to avoid or reduce significant harm
  • Documentation: Maintain evidence of DNSH compliance for each activity

Minimum Safeguards

Taxonomy-aligned activities must meet minimum safeguards based on international standards:

  • Human rights: UN Guiding Principles on Business and Human Rights
  • Labor standards: ILO core labor standards (freedom of association, collective bargaining, child labor, forced labor)
  • Corruption: OECD Guidelines for Multinational Enterprises, UN Convention against Corruption
  • Tax good governance: OECD BEPS minimum standards
  • Fair competition: EU competition law

Compliance Evidence

Companies must have policies and procedures in place to ensure compliance with minimum safeguards. This includes due diligence processes, grievance mechanisms, and regular monitoring. Evidence of compliance must be documented and available for disclosure under CSRD.

DNSH and Minimum Safeguards Are Non-Negotiable

Even if an activity substantially contributes to an environmental objective, it cannot be taxonomy-aligned if it causes significant harm to other objectives or fails to meet minimum safeguards. These are absolute requirements.

Disclosure Requirements

Under CSRD, companies must disclose taxonomy alignment metrics that link sustainability performance directly to financial statements. Disclosures are required for the six environmental objectives, with climate objectives having mandatory disclosure from the outset.

Key Disclosure Metrics

Companies must disclose three primary metrics for each environmental objective:

  • Taxonomy-aligned turnover: Percentage of revenue from taxonomy-aligned activities
  • Taxonomy-aligned capex: Percentage of capital expenditure on taxonomy-aligned activities
  • Taxonomy-aligned opex: Percentage of operating expenditure on taxonomy-aligned activities

Eligible vs Aligned Turnover

Companies must disclose both eligible and aligned turnover:

  • Eligible turnover: Revenue from activities covered by the taxonomy framework
  • Aligned turnover: Revenue from activities that meet all four taxonomy criteria
  • Alignment ratio: Aligned turnover as a percentage of eligible turnover

Phase-In of Objectives

Disclosure requirements are phased by environmental objective:

  • Climate objectives (mitigation & adaptation): Mandatory from first reporting year
  • Water, circular economy, pollution, biodiversity: Mandatory from 2024 for large companies, 2026 for SMEs
  • Non-EU companies: Phased based on CSRD wave implementation

Financial Institution Disclosures

Financial institutions (banks, asset managers, insurers) have additional disclosure requirements. They must disclose the taxonomy alignment of their assets, investments, and lending portfolios. This includes green asset ratios (GAR) for banks and taxonomy alignment of investment portfolios for asset managers.

Disclosures Link ESG to Financials

Taxonomy disclosures directly link sustainability performance to financial metrics (revenue, capex, opex). This enables investors to assess the sustainability of a company's business model and capital allocation decisions.

Eligibility vs Alignment (Important)

Understanding the distinction between eligibility and alignment is critical for taxonomy compliance.

Eligibility

Activity is covered by the taxonomy

Framework includes the activity

Alignment

Activity meets all criteria

Substantial contribution + DNSH + safeguards + technical criteria

Not all eligible activities are aligned

Alignment determines actual sustainability classification

Eligibility indicates scope, while alignment indicates actual sustainability performance

What Companies Must Disclose

Under CSRD, companies must report taxonomy alignment metrics.

% of revenue aligned with taxonomy

% of capex aligned

% of opex aligned

Taxonomy disclosures link sustainability to financial metrics

These metrics allow investors to directly compare companies on sustainable economic exposure

Companies may show low current alignment but high taxonomy-aligned capex, indicating transition toward sustainability

Key Financial Mechanisms

The EU Taxonomy affects companies and investors through specific financial mechanisms.

1. Capital Allocation Mechanism

Capital flows toward aligned activities

→ Investment shifts to sustainable activities

2. Investment Screening Mechanism

Investors use taxonomy for decisions

→ Sustainable fund screening and selection

3. Valuation Mechanism

Aligned assets may receive premium

→ Potential valuation uplift for aligned activities

4. Regulatory Mechanism

Required for compliance and disclosure

→ CSRD reporting requirement

Financial Outputs:

Capital inflows/outflows - investment toward aligned activities

Inclusion/exclusion from funds - screening and selection

Premium/discount - valuation impact for aligned assets

Mandatory disclosure impact - regulatory compliance

Real Financial Pathways

The EU Taxonomy affects financial outcomes through concrete cause-effect chains.

Capital Flow Pathway

Taxonomy Alignment → Investor Preference → Increased Investment → Lower Cost of Capital

Screening Pathway

Non-Aligned Activity → Exclusion from Sustainable Funds → Reduced Capital Access

Valuation Pathway

High Alignment → Perceived Lower Risk → Valuation Premium

Compliance Pathway

CSRD Requirement → Taxonomy Disclosure → Reporting Impact → Cost / System Impact

Strategic Shift Pathway

Low Alignment → Strategic Transition → Capex Reallocation

Transition Pathway

Low Alignment → Increased Sustainable Capex → Future Alignment → Improved Capital Access

Impact on Business & Strategy

The EU Taxonomy influences how companies operate and make strategic decisions.

Operational Impact

Measurement and classification

Strategic Impact

Shift toward aligned activities

Investment Impact

Capex decisions influenced

EU Taxonomy influences what companies invest in and how they position their business

Taxonomy alignment influences how companies position themselves to investors and regulators

Challenges & Limitations

EU Taxonomy implementation presents technical and analytical challenges.

Complexity of criteria

Data requirements

Interpretation challenges

Sector coverage gaps

Partial coverage - Not all economic activities are fully covered by taxonomy

Implementation requires detailed technical and financial analysis

Key Takeaways

EU Taxonomy defines what is environmentally sustainable

It is a classification system used in regulation and finance

Requires meeting strict criteria (contribution + DNSH + safeguards)

Links ESG to financial metrics (revenue, capex, opex)

Influences capital flows and investment decisions

Critical for CSRD compliance

EU Taxonomy defines what is sustainable—and therefore where capital flows.

Classification drives capital—what is not classified as sustainable may struggle to attract investment.

Example

A renewable energy project may qualify as taxonomy-aligned, attracting investor capital and improving financing conditions.

Frequently Asked Questions