EU Taxonomy FAQ: Scope, Deadlines, and Guidance on Interpretation
The EU Taxonomy Regulation is complex, and the Omnibus Regulation has changed both its scope and reporting methodology in recent months. The European Commission has provided several FAQ documents to assist with interpretation and implementation. In this article, we outline who is currently affected, what has changed, and which FAQ documents are currently in effect.
The EU Taxonomy Regulation at a Glance
The EU Taxonomy Regulation ((EU) 2020/852) classifies economic activities based on whether they make a significant contribution to at least one of six environmental objectives, including climate action, climate change adaptation, and the transition to a circular economy. Currently, a total of 243 economic activities are assigned to these objectives. Affected companies identify and report, through a five-step process, the taxonomy-eligible and taxonomy-compliant portions of three indicators: green revenue, green investments, and green operating expenses.
Who is affected by the EU taxonomy today?
The regulation already applies to fiscal years beginning in 2021, initially with a limited scope of application for large capital market-oriented companies. As a result of the Omnibus Package, the regulation is now linked to the new, significantly narrower scope of the CSRD: Companies with more than 1,000 employees and net revenue exceeding €450 million are subject to mandatory reporting. The expansion to all other large companies, originally planned for 2025, will therefore no longer take place in its original form. Details on the scope and timeline of the CSRD, to which the taxonomy reporting requirement is linked, can be found in our article on the CSRD Implementation Act.
For companies from third countries with EU revenue exceeding €450 million, the obligation applies through their EU subsidiary or branch, but only starting with the 2028 fiscal year—one year later than for EU companies. Companies that are currently subject to reporting requirements but will fall outside the new scope in the future will no longer be required to report, but they must still expect inquiries from banks, investors, and customers who need the key figures for their own reporting purposes.
What’s Still in the Works
The simplification process is not yet complete. On March 17, 2026, the European Commission launched a public consultation on two draft regulations intended to further simplify the technical assessment criteria of the Climate and Environmental Acts; the sectors affected include manufacturing, energy, transportation, construction, real estate, and water and waste management. The adoption of the final regulations was scheduled for summer 2026, with implementation expected to begin in the 2027 fiscal year. In practice, this means that while the criteria are still evolving, the data requirements remain unchanged. Those who store documentation for each activity in a structured and versioned manner can track changes to the criteria rather than having to start the analysis from scratch each time.
How the Omnibus Has Changed the Reporting Methodology
In addition to its scope of application, the Omnibus Regulation has also changed the way information is reported. Delegated Regulation (EU) 2026/73, published in the Official Journal of the European Union on January 8, 2026, significantly simplifies the reporting forms:
- The separate templates for fossil gas and nuclear energy (Appendix XII) have been eliminated and integrated into streamlined summary tables.
- Overall, the number of required data points is decreasing by about 64% for non-financial companies and by about 89% for credit institutions.
- A new materiality threshold of 10% allows economic activities to be excluded from the taxonomy eligibility and compliance assessment if, taken together, they account for less than 10% of the respective KPI value.
- Non-financial companies can omit the OpEx KPI entirely if operating expenses are not material to their business model.
The new methodology is optional for fiscal year 2025 and mandatory starting with fiscal year 2026. For fiscal year 2025, companies may alternatively continue to use the previous methodology in accordance with Delegated Regulation (EU) 2021/2178.
Which FAQ documents are currently in effect?
The European Commission has published several rounds of FAQs, each of which explains the regulations in effect at the time:
- 2023 (C/2023/305 and C/2023/267): 34 and 187 questions, respectively, regarding disclosure requirements and technical evaluation criteria under the original methodology.
- April 30, 2026 (C/2026/2558): The most recent and, for practical purposes, currently most important notice, containing 17 questions. In particular, it provides specific guidance on the initial application of the Omnibus Act (EU) 2026/73, the newly introduced materiality concept, and disclosure requirements for financial institutions in connection with special purpose vehicles (SPVs).
As with the regulation itself, the FAQ documents are available in all official EU languages, including German. They are not legally binding and neither introduce new requirements nor expand existing obligations; rather, they are intended solely to aid in interpretation.
Stay on top of things with CONSUST
The combination of several rounds of FAQs, a new methodology, and a revised scope currently makes the EU Taxonomy more confusing, not simpler. For a more detailed roadmap on how to set up revenue, CapEx, and OpEx KPIs in a data-driven and audit-ready manner, see our white paper “EU Taxonomy 2026: From Reporting Form to Management Tool.” We’ve also integrated the current reporting forms, materiality thresholds, and FAQ interpretations into our FramesCube software, so you can map out the entire five-step process—all the way to the final report—in a structured manner. Contact us for a no-obligation consultation.
