The EU Taxonomy is a classification system establishing a list of environmentally sustainable economic activities. This checklist guides companies and financial market participants through the three-step process of assessing Taxonomy alignment.
Phase 1: Eligibility Assessment
Before assessing alignment, you must determine if the economic activity is covered by the Taxonomy (Taxonomy-eligible).
- Identify the Economic Activity: Map your company's revenue-generating activities, capital expenditures (CapEx), and operating expenditures (OpEx).
- Check the Delegated Acts: Cross-reference these activities against the descriptions in the Climate Delegated Act and the Environmental Delegated Act.
- Confirm Eligibility: If the activity matches a description in the Delegated Acts, it is Taxonomy-eligible. If not, it is non-eligible (which does not necessarily mean it is harmful, just not covered yet).
Phase 2: Substantial Contribution (SC)
For an eligible activity to be aligned, it must make a substantial contribution to at least one of the six environmental objectives.
- Select the Objective: Choose the primary environmental objective the activity contributes to (e.g., Climate Change Mitigation).
- Review Technical Screening Criteria (TSC): Locate the specific TSC for substantial contribution for that activity in the relevant Delegated Act.
- Assess Compliance: Gather data to prove the activity meets or exceeds the quantitative or qualitative thresholds set in the TSC (e.g., specific emissions limits, energy efficiency standards).
Phase 3: Do No Significant Harm (DNSH)
An activity cannot be considered sustainable if it harms other environmental objectives.
- Review DNSH Criteria: Locate the specific DNSH criteria for the activity regarding the other five environmental objectives.
- Conduct Climate Risk Assessment: For the Climate Change Adaptation objective, perform a robust climate risk and vulnerability assessment.
- Verify Compliance: Ensure the activity meets all applicable DNSH thresholds (e.g., water management plans, pollution prevention measures, circular economy requirements).
Phase 4: Minimum Social Safeguards (MSS)
Alignment requires compliance with foundational human rights and labor standards at the entity level.
- Human Rights Due Diligence: Implement processes aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.
- Labor Rights: Ensure compliance with the ILO Declaration on Fundamental Principles and Rights at Work.
- Anti-Corruption and Taxation: Maintain robust anti-bribery, anti-corruption, and fair taxation policies.
- Verify No Convictions: Ensure the company has not been convicted of serious breaches in these areas.
Phase 5: Calculation and Reporting
- Calculate KPIs: Calculate the proportion of Turnover, CapEx, and OpEx derived from Taxonomy-aligned activities.
- Prepare Disclosures: Format the KPIs using the mandatory templates provided in the Disclosures Delegated Act.
- Publish in Annual Report: Include the Taxonomy disclosures in the sustainability statement of your annual report, as required by the CSRD.