EU Taxonomy FAQs: Staying on Top of Things with CONSUST
European Union regulations are often difficult to understand, and the sheer volume of legal texts makes it hard to keep track of everything. This is particularly true of the EU Taxonomy Regulation. The EU has therefore published
The EU Taxonomy Regulation at a Glance
The EU Taxonomy Regulation establishes a clear framework for classifying “green” or “sustainable” economic activities in the EU. It defines when an economic activity is considered sustainable. As a result, such companies stand out positively and attract more investment. The legislation aims to promote environmentally friendly business practices, focusing on six environmental objectives: climate action, adaptation to climate change, sustainable use and protection of water and marine resources, transition to a circular economy, prevention and reduction of pollution, and protection and restoration of biodiversity.
If you are affected by the EU Taxonomy, you must demonstrate how sustainable—or “green”—your business activities are. To do so, you must determine and report the taxonomy-eligible and taxonomy-compliant portions of three key metrics: revenue, capital expenditures (CapEx), and operating expenses (OpEx). The scope of application has been significantly narrowed by the omnibus procedure: Starting with the 2025 fiscal year, only large capital market-oriented companies with an annual average of more than 1,000 employees and net revenue exceeding €450 million are subject to reporting requirements. The relevant legal basis is provided by the Taxonomy Regulation (EU) 2020/852 and the Delegated Regulation (EU) 2021/2178 regarding Article 8, both of which have been in effect since the beginning of 2026 in the version amended by Delegated Regulation (EU) 2026/73. Details on the simplification can be found in the following section.
January 2026 Update: What the Omnibus Act Has Changed
On January 8, 2026, the European Commission published Delegated Regulation (EU) 2026/73 in the Official Journal of the EU. It was adopted and has been in effect since January 1, 2026. For the 2025 fiscal year, Article 4 of the Regulation provides for an option: Companies may choose whether to report in accordance with the new rules or continue to report under the previous version. Starting with the 2026 fiscal year, the new version is mandatory.
The Regulation amends three existing legal acts: the Disclosure Regulation (EU) 2021/2178 with respect to Article 8, as well as the technical evaluation criteria in Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486. Three changes have the greatest practical impact.
The Materiality Principle. Business activities that, when totaled by metric, account for less than 10% of revenue, CapEx, or OpEx no longer need to be individually assessed for taxonomy eligibility and taxonomy compliance. They are reported separately as immaterial.
Shorter reporting forms. The number of templates and data points has been reduced.
Revised DNSH criteria. The requirements for the environmental goal “Prevention and Reduction of Environmental Pollution” have been relaxed in certain areas.
A draft of a further Commission Notice regarding the interpretation of the 10% threshold has been available since December 17, 2025; so far, it is only available in English. Changes to the content are possible before the final publication; a German version is expected in 2026.
This does not mark the end of the reform process. The revised delegated regulations on climate and environmental targets are expected in the summer of 2026, and supplementary guidelines from the European supervisory authorities are expected by October 2026.
White Paper: EU Taxonomy 2026 – From Reporting Form to Policy Tool
What are the EU Taxonomy FAQs about?
The expansion of the scope of the EU Taxonomy in 2025 initially affected a large number of companies. To support them in implementing the changes, the European Commission published several EU Taxonomy FAQs in its Official Journal as early as 2023. In June 2023, a document consisting of four questions was published (2023/C 211/01). This document focused in particular on the interpretation and implementation of the minimum safeguards set forth in Article 18 of the Regulation. Two additional FAQs, which followed in October, are significantly more comprehensive. Notice C/2023/305 contains 34 questions and answers regarding the disclosure requirements of the EU Taxonomy. The second notice, C/2023/267, contains 187 questions regarding the establishment of technical assessment criteria for significant economic activities.
What is the significance of the EU Taxonomy FAQs?
The two more detailed FAQs were already adopted by the European Commission in December 2022 and published in the Official Journal of the EU in October 2023 as a “Commission Notice” without any significant changes. Like the regulation itself, the FAQs are available in all official languages, including German. Unlike the regulation, however, the FAQs are not legally binding. They neither introduce additional requirements nor expand existing rights and obligations. The purpose of the EU Taxonomy FAQs is therefore solely to clarify the existing provisions in the applicable legislation.
Stay on top of things with CONSUST
Even though the EU Taxonomy FAQs do not constitute a supplement to the law, they are nonetheless relevant as a guide for implementing the legal requirements within your company. However, reviewing the more than 200 questions can be a challenge. CONSUST enables your company to efficiently implement the EU Taxonomy using our FramesCube software. In addition to all reporting requirements, the FAQs are also integrated into the software, allowing you to use them in a time-saving manner. The FramesCube EU Taxonomy software maps the entire five-step process—all the way to the final EU Taxonomy report—in a structured workflow. Contact us for a no-obligation consultation and learn more about the FramesCube software and its potential for your company.
