Highlights

Simplified reporting templates and a new materiality concept are among the changes for companies that report under the EU Taxonomy, following targeted amendments from the European Commission. 

The EU Taxonomy currently applies to all companies in scope of the CSRD1, which are likely to change as a result of the ongoing Omnibus discussions. 

The amendments apply for 2025 reporting periods, with an option to delay their application until the 2026 reporting period.  

Jan A. Müller

Partner, Audit

KPMG in Germany

The EU Taxonomy aims to encourage sustainable investment by providing decision-useful information to investors. Introducing a materiality concept and simplifying the reporting templates will be a step in the right direction. However, whether EU Taxonomy legislation will achieve its ultimate goal will depend on the outcome of ongoing scoping discussions.

Jan A. Müller

Chair, Taxonomy Working Group

What areas will change? 


The amendments relate to the following key areas:

 Non-financial companiesFinancial companies
New reporting templates

A summary table is introduced in addition to the three activity tables:

  • turnover;
  • capital expenditure (capex); and 
  • operating expenditure (opex). 

The activity templates are less granular, reducing the number of individual data points from 78 to 28.

The separate reporting templates for gas and nuclear activities are deleted.

The templates are significantly revised to reduce the number of data points by 89 percent (mainly for credit institutions).

The extensive reporting templates on financing gas and nuclear activities are deleted and information is captured on an aggregated level in the general templates.

Reporting on the trading book and fee and commission income is only required for credit institutions from 2027. 

Introducing a materiality concept

Economic activities that cumulatively account for less than 10 percent of turnover, capex or opex can be reported separately as non-material.

The entire opex template may be omitted if opex is deemed not material to the company’s business model. Instead, the company discloses its total opex and explains why it is not material. 

A materiality threshold is introduced for exposures where the use of proceeds is known. Financial companies do not need to collect information if eligible or aligned exposures are less than 10 percent of the total known use-of-proceeds exposures.

Credit institutions may additionally omit reporting templates relating to activities that equal less than 10 percent of total turnover.

Do No Significant Harm (pollution)The DNSH criteria for ‘pollution prevention and control’ related to the use and presence of chemicals are simplified (Appendix C). The targeted changes cover criteria across sectors that the Commission considers most problematic for companies to demonstrate.   
Assets covered in the key performance indicator (KPI) calculation 

Fewer assets need to be considered in taxonomy ratios. Additional assets are excluded from the denominator of the calculation – e.g. cash, derivatives, goodwill and commodities – but also exposures towards companies that do not report EU Taxonomy disclosures.

Companies may decide to include those if counterparties voluntarily report, or when the use of proceeds by the counterparty is known.

 

Additionally, financial companies are granted a new relief to omit EU Taxonomy disclosures by stating that they do not claim environmentally sustainable activities. This relief is in light of the ongoing longer-term reviews of reporting requirements and technical screening criteria (TSC).  The relief ceases to apply with the reporting period 2027.

Next steps

The amendments are now subject to a scrutiny period of four months (extendable by two months) in which the European Parliament and the Council can raise objections. If no objections are raised, the amendments will become effective on 1 January 2026 for 2025 reporting periods. Companies are allowed to delay adopting the amendments to reporting period 2026.

The European Commission is undertaking a more comprehensive review of the TSC, in particular of the DNSH criteria, with the aim to make them simpler, more usable and more closely aligned with other EU legislation. 

Discussion on changing the scope of the CSRD (and consequently the EU Taxonomy) continues as part of the Omnibus discussions.


 

1 The EU Corporate Sustainability Reporting Directive.