Since 1 January 2026, Delegated Regulation (EU) 2026/73 has simplified the reporting of EU Taxonomy indicators, and Directive (EU) 2026/470 has raised the CSRD thresholds on which the circle of companies required to report them depends. Several revisions are still in preparation.
This article answers five questions: who reports, what changed in 2026, how the 10% threshold works, which indicators are expected, and what is not yet adopted. The facts were checked against institutional sources as of 9 October 2026. The broader framework is presented in our article on the European Green Deal.
Who must report under the EU Taxonomy?
Any company required to publish a sustainability report under Articles 19a or 29a of the Accounting Directive publishes the share of its turnover, CapEx and OpEx associated with sustainable activities (Article 8 of Regulation (EU) 2020/852). The scope is therefore defined by reference to these two articles of the Accounting Directive, which Directive 2026/470 amended.
In practice, the first group of CSRD companies is covered for financial years 2024 to 2026, subject to the exemption option that member states may open for 2025 and 2026. From financial year 2027, only companies with more than 1,000 employees and more than EUR 450 million in net turnover remain concerned. Member states must transpose the directive by 19 March 2027; this article describes the European texts. Our article on the CSRD directive details this scope.
The Taxonomy classifies economic activities according to their contribution to six environmental objectives: climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention and control, and the protection and restoration of biodiversity and ecosystems (Article 9 of the Regulation).
What did Delegated Regulation 2026/73 change?
Delegated Regulation (EU) 2026/73, adopted on 4 July 2025, was published in the Official Journal on 8 January 2026 and entered into force on 28 January 2026. It applies from 1 January 2026. It amends the "Disclosures" delegated act (Regulation 2021/2178) and, for some criteria, the acts on climate (2021/2139) and the environment (2023/2486).
For the financial year starting in 2025, companies may still apply the former texts or the new regime, at their choice. Reports for financial year 2026, published in 2027, fall under the new regime.
The text introduces the 10% materiality threshold and substantially shortens the reporting templates (recital 13). The Commission states that it significantly reduced the number of reported data points. It also simplifies the do no significant harm (DNSH) criteria relating to chemicals. The technical criteria for substantial contribution to climate mitigation and adaptation are not modified by this text.
How does the 10% threshold work?
For non-financial companies, a company may skip assessing the eligibility and alignment of activities whose cumulative share is below 10% of the indicator's denominator, applied separately to turnover and CapEx. For OpEx, the rule differs slightly. The amounts concerned are disclosed separately as non-significant.
The detail, indicator by indicator:
- Turnover: activities whose cumulative turnover is below 10% of the indicator's denominator may be left unassessed.
- CapEx: same rule, with 10% of the CapEx denominator.
- OpEx: if operating expenditure is not material to the business model, the company may skip assessing all OpEx, provided it discloses the total denominator and explains why. Otherwise, the 10% threshold applies.
The turnover, CapEx and OpEx concerned are disclosed separately as non-significant. Asset managers and credit institutions benefit from a comparable 10% threshold logic for their own indicators.
Which indicators must a non-financial company report?
A non-financial company reports the share of its turnover, CapEx and OpEx linked to eligible activities, then to activities aligned with the Taxonomy (Article 8 of Regulation 2020/852). Each is expressed as a share of the relevant total. The two notions are distinct, and alignment is the more demanding.
An activity is environmentally sustainable if it meets four conditions (Article 3 of the Regulation):
- it contributes substantially to one or more of the six environmental objectives;
- it does no significant harm to any of the other objectives (DNSH);
- it is carried out in compliance with minimum safeguards;
- it complies with the technical screening criteria established by the Commission.
An activity is eligible when it is among those covered by the Taxonomy, and aligned when it also meets these four conditions.
The information appears in the management report and the sustainability statement. The revised ESRS allow it to be presented in a separate annex (ESRS 1, §106), an option usable from financial year 2026 even with the former standards. The verifier checks compliance with Article 8: the H2A guidelines detail its procedures on the non-material nature of excluded activities, eligibility and alignment.
In Kabaun, a feature helps assess the alignment of activities with the substantial contribution and DNSH criteria (REG-004), without removing the need to identify the activities.
What is still under revision?
Two revisions are in preparation: the technical criteria and the "Disclosures" act. Neither was adopted as of 9 October 2026. The timelines are the Commission's, they have already slipped, and we do not prejudge the final content or the dates.
- Technical criteria: draft delegated acts amending Regulations 2021/2139 and 2023/2486 "to improve usability" were published on 17 March 2026, with feedback until 14 April 2026. Adoption was planned for the third quarter of 2026 according to the Commission in March 2026, then for the fourth quarter of 2026 according to its register updated on 22 September 2026.
- "Disclosures" act: a Commission call for advice to the European Supervisory Authorities (ESMA, EBA, EIOPA), sent in March 2026, covers OpEx indicators for non-financial companies, some banking indicators, insurers' underwriting and other targeted simplifications. Their advice is expected in October 2026, with adoption targeted for the first quarter of 2027 and entry into force targeted for the third quarter of 2027.
For financial undertakings, a transitional relief applies until 31 December 2027, under conditions: Articles 2 to 8 of Regulation 2021/2178 do not apply to those that do not claim any Taxonomy-associated activities.
These revisions may change the current rules, including the 10% threshold. We do not prejudge their content or their timing.
What should be prepared for financial year 2026?
For financial year 2026, companies required to report apply Regulation 2026/73. Three actions are needed: map the activities and their weight in turnover and CapEx to spot those the 10% threshold allows you not to assess, build an evidence file on eligibility and alignment for each assessed activity, and decide whether OpEx is material to the business model. Document every choice: the verifier checks Article 8.
FAQ
Is the EU Taxonomy being abolished? No. Regulation 2020/852 remains in force, and Delegated Regulation 2026/73 simplifies its implementation without removing it. It applies to companies required to publish a sustainability report under Articles 19a or 29a of the Accounting Directive.
Must my company report Taxonomy indicators for 2026? If it is required to publish a sustainability report for financial year 2026, yes: the new regime applies to that year. Directive 2026/470 does, however, allow member states to exempt some companies for 2025 and 2026. Companies that enter the scope only from financial year 2027 are concerned from that date, if they exceed both thresholds.
Is the 10% threshold final? Nothing guarantees it. It results from Regulation 2026/73, and the revision of the "Disclosures" act, targeted for the first quarter of 2027, may still change the rules.
What is the difference between eligible and aligned? An eligible activity is among those covered by the Taxonomy. An aligned activity also meets four conditions: substantial contribution, no significant harm, minimum safeguards and technical screening criteria.
Have the technical criteria already been revised? No. The draft revisions published on 17 March 2026 were not adopted as of 9 October 2026, with adoption planned for the fourth quarter of 2026 according to the Commission register.
Does the verifier check the Taxonomy? Yes. Its opinion covers compliance with Article 8 of the Taxonomy Regulation under Directive 2026/470, and the H2A specifies its procedures on eligibility, alignment and activities excluded as non-material.
Conclusion
For financial year 2026, the Taxonomy is reported under Delegated Regulation 2026/73, with a 10% materiality threshold per indicator, and from 2027 only companies above the two CSRD thresholds remain concerned. Two revisions, of the technical criteria and of the "Disclosures" act, are under way and may still change the detail. Start by mapping your activities and their weight in turnover and CapEx: it is the starting point of every indicator.
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