The European Union (EU) has some of the most advanced, progressive, and complex corporate and investor sustainability laws and reporting requirements in the world. Under the banner of an 'EU Green New Deal', Europe is implementing a sweeping set of sustainability measures, including the EU Taxonomy for Sustainable Activities, designed to fight climate change, support sustainable finance and innovation, and make Europe the first climate-neutral continent by 2050.
However, as we all know, big economic change also creates new compliance and reporting obligations for companies and investors, and the EU's integration of the EU Taxonomy into sustainability reporting is no different. All of Europe new sustainability rules, standards, and legislation can be challenging to track, so we’ve prepared this guide to summarize the EU Taxonomy for Sustainable Activities, EU Taxonomy reporting requirements, and what it means for organizations in 2024.
The EU Taxonomy is a common classification system for sustainable economic activities, projects, and investments
When we refer to "taxonomy," we are defining a way to categorize or classify information. In this case, the EU Taxonomy provides a checklist or criteria to decide whether something is, or isn't sustainable, according to the EU's definitions.
The taxonomy is designed to screen and assess the sustainability of:
Unfortunately, because the EU economy is complex, the EU Taxonomy is also fairly complicated. Today, the full taxonomy is currently around 600 pages. Our goal is to summarize the basics here so the EU Taxonomy feels more clear, manageable, and actionable for your organization.
It's also important to note that while the taxonomy is primarily a screening tool, there are also EU Taxonomy-linked sustainability reporting requirements, which mandate certain EU companies and investors to disclose which of their activities do and don't meet the EU Taxonomy's criteria in their financial reporting.
The EU Taxonomy regulation defines a sustainable economic activity as any activity that:
The six key environmental objectives of the EU Taxonomy are:
For example, under climate change mitigation, the EU defines creating and developing modern infrastructure for rail transport as a sustainable economic activity, because it allows more people to travel via public transportation, thereby reducing greenhouse gas (GHG) emissions from cars. Each of the six environmental objectives list different activities and criteria for what meets the definition of 'sustainable'.
Under EU law, the taxonomy is required to be reviewed and updated every three years. When it comes to defining ‘substantial contribution’ and ‘significant harm’, EU regulators note that:
Sustainable activities can also be classified under multiple environmental objectives and benefits. For example, under the EU Taxonomy, renewable energy development, maintenance, and investment meets the criteria for (1) climate change mitigation, (2) climate change adaptation, and, likely, (3) pollution prevention and control.
Within the EU's defined sustainable activities that contribute to its environmental objectives, the taxonomy also defines two classification categories for activities that help achieve those objectives longer-term, but may not technically be considered 'sustainable' under the taxonomy: (1) enabling activities and (2) transitional activities.
Enabling activities are activities that allow other sustainable activities to occur, like, for example, changing the electricity grid to allow more renewable energy to be used. By comparison, transitional activities are "placeholder" or "best current available option" activities where there is no technologically or economically feasible lower-carbon alternative.
The taxonomy applies to companies, organizations, asset managers, and financial advisors that are legally required to report under the Sustainable Financial Disclosure Regulation (SFDR) and the Corporate Sustainability Reporting Directive (CSRD). The taxonomy can also be used as a reference by any investor, SME, bank, or organization so they can better understand whether their economic activities are considered environmentally sustainable.
At present, 13 economic sectors are covered under the taxonomy. The EU has stated that they’re working to expand the sectors beyond the ones listed below and look to cover all industries in the future:
Out of the EU Taxonomy's six environmental objectives, only (1) climate change mitigation and (2) climate change adaptation have officially been designed, approved, and released for use. The other remaining four taxonomy objectives will be released over the course of 2024.
To use the taxonomy, a company or investor should review the taxonomy's classification criteria, and compare it with their investments and activity to see what percentage of activity falls under the criteria. To officially be valid or aligned under the Taxonomy as a sustainable activity, economic activity must meet four criteria:
The taxonomy’s primary purpose is to help keep the EU on track for the climate and energy targets set in the European Green Deal. Europe is actively working to become a “green” economy and the taxonomy is meant to guide investment and business activity in more sustainable directions to help it get there. The EU Taxonomy is also part of the EU's effort to combat greenwashing activities and, instead, promote activities that are climate positive.
As a checklist, the taxonomy has two main uses: as a classification tool and as a screening tool. As a classification tool, it helps organizations, investors, and policymakers understand what is considered a sustainable activity. As a screening tool, it creates more clarity for these stakeholders around determining if investments are environmentally sustainable.
Moreover, the Corporate Sustainability Reporting Directive (CSRD) and Sustainable Finance Disclosure Regulation (SFDR) both require entities to share information on how their business activities are in alignment with the EU taxonomy.
In EU corporate financial reporting, the EU Taxonomy is linked with financial disclosure. Under the EU’s Non-Financial Reporting Directive (NFRD) and CSRD, eligible companies must track and report:
At the end of 2022, CDP also announced they will be piloting taxonomy questions for climate change mitigation and adaptation, starting in 2023 and 2024.
For investors, the EU Taxonomy also has important implications. On April 6, 2022 the EU adopted technical standards to be used by financial market participants when disclosing sustainability-related information under the SFDR. These regulations specify the exact content, methodology, and presentation of information that needs to be disclosed. Under these rules, financial market participants must provide detailed information about how they address and reduce any possible negative impacts that their investments may have on the environment and society in general. As of October 31, 2022, investors also need to disclose if their portfolios are exposed to gas and nuclear activities covered by the taxonomy. These new requirements are also designed to help investors assess the sustainability performance and credibility of financial products.
Brightest helps hundreds of companies measure EU sustainability reporting KPIs and manage their ESG compliance activities in one unified system
In a sense, the EU Taxonomy is a "unifying framework" within the EU's 2050 Sustainable Action Plan - designed to tie together sustainable financial and corporate investment in a single classification system. As you can likely tell from the length of this article alone, there are a lot of important new EU sustainability laws and economic changes taking effect in 2024 and future years. In fairness, it can feel very complex and daunting. However, from a positive perspective:
For organizations in the early stages of their sustainability reporting journey, we have a few general recommendations, additional reading, and suggested next steps:
Materiality assessment - The principle of Materiality is embedded in most of these new EU legislations, particularly the concept of double materiality. Materiality essentially asks and attempts to answer a fundamental question: what are the most important (re: material) ESG and sustainability risks and considerations for a business or investment? If your organization hasn't already done so, a materiality assessment can help determine what your top sustainability goals, targets, risks, and priorities should be in relation to regulatory and investor sustainability reporting. In turn, this can help clarify where to focus, what to prioritize, and what aspects of pending or forthcoming EU sustainability legislation matter most to you.
Understand the EU Taxonomy in depth - A full, in-depth breakdown of the EU Taxonomy is outside the scope of this piece, but it is critical that, if your organization meets EU sustainability disclosure and/or due diligence criteria, you work with your leadership, directors, legal counsel, auditors, and other stakeholders to learn your organization's specific timeline and obligations to use the taxonomy. Make sure you're clear if your organization is or will be required to report on SFDR and/or CSRD, and if it currently discloses information to CDP. If yes, you’ll also need to start aligning those disclosures with the EU taxonomy. Start with the two taxonomy environmental objectives that are fully approved, and start preparing to assess your activities along the remaining four objectives so you can be ready when they're approved.
Alignment between financial and sustainability data systems and process - While this might go without saying, in order to report your organization's sustainable activities and investments, you need to know what they are - with a high degree of accuracy. Your materiality process can help guide you toward the main sustainability themes you may need to focus on and collect data around. Many organizations start their sustainability reporting with relatively simple spreadsheets, surveys, and documents, but things can get complex fast - particularly for larger companies if you're trying to track all of your sustainable and non-sustainable CAPEX and OPEX. If you're an organization with a medium-to-large or complex environmental and/or operational footprint, you likely need dedicated sustainability reporting and data management software, like the kind we design here at Brightest to help organizations stay compliant. Ongoing report archiving, version control, and governance are also important to think about, since you'll be preparing taxonomy disclosures every year.
Further reading - Our free guides to sustainability measurement, sustainability reporting, and ESG reporting provide additional, detailed guidance and insights on how to measure and report your sustainability performance. Or, if you're ready to up-level your sustainability reporting and data maturity to meet ESRS requirements, please contact us for a free assement or demo of Brightest's intelligent, award-winning ESG platform.