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Appendix A -- Delegated Reg. 2021/2139

Climate Risk & Vulnerability Assessment

The CRVA is the mandatory process for demonstrating that a building activity is resilient to physical climate risks. Defined in Appendix A of the Climate Delegated Act, it applies to every activity seeking taxonomy alignment under Objective 2.

Legal Basis

The CRVA process is defined in Appendix A of Commission Delegated Regulation (EU) 2021/2139, which supplements the Taxonomy Regulation (EU) 2020/852. It forms the core of the technical screening criteria for climate adaptation across all sectors.

For buildings specifically, activities under NACE codes F41 and F43 (construction and renovation) must complete this process to demonstrate substantial contribution to Objective 2 or to satisfy the DNSH requirement for Objective 1.

The key principle: adaptation measures must be based on forward-looking climate projections, not historical observations alone. The regulation explicitly requires the use of climate scenarios over the expected lifetime of the asset.

Key Requirements

Forward-looking climate projections (not just historical data)
Multiple climate scenarios (RCP 2.6, 4.5, and 8.5)
Minimum 10-year horizon; 30+ years for major infrastructure
State-of-the-art, highest available resolution
Consistent with local and regional adaptation strategies
No maladaptation -- solutions must not shift risk elsewhere

The 6-Step Process

Appendix A defines a structured progression from hazard identification to ongoing monitoring. Each step builds on the previous one.

1

Screening

Screen the activity against the full list of physical climate hazards in Appendix A. Identify which hazards are material to the building based on its location, function, and expected lifetime (minimum 10 years, up to 30+ for major assets).

Use climate projections, not historical data. Consider both the current climate and future scenarios over the lifetime of the economic activity.

2

Climate Risk Assessment

For each material hazard, assess the probability and severity of impact. This requires forward-looking climate data under multiple RCP scenarios, ideally at a resolution relevant to the building site.

The regulation calls for "state of the art" and "best available" projections. For localised hazards like heat stress, regional models may not be sufficient.

3

Risk Evaluation

Evaluate vulnerability and exposure. Determine whether existing conditions or planned design already mitigate the risk, or whether additional adaptation measures are needed.

Consider cascading risks -- a flood risk combined with power grid vulnerability, for example. Evaluate the interaction between hazards.

4

Adaptation Plan

Define adaptation solutions for each material risk. Solutions must reduce the identified risk without creating maladaptation, and must be consistent with local, sectoral, and regional adaptation strategies.

Adaptation measures range from structural (cool roofs, drainage) to nature-based (green infrastructure, permeable surfaces) to operational (monitoring, early warning systems).

5

Implementation

Implement the adaptation plan within an agreed timeframe. For new construction, measures must be integrated from design stage. For renovation, a defined implementation schedule is required.

Document the measures taken and ensure they are verifiable by third-party auditors.

6

Monitoring & Review

Establish a monitoring framework to track the effectiveness of adaptation measures over time. The plan must be reviewed and updated as new climate data becomes available.

Climate projections are regularly updated. A CRVA is not a one-time exercise -- the regulation expects ongoing vigilance.

RCP Scenarios Explained

The taxonomy requires assessments under multiple Representative Concentration Pathway (RCP) scenarios. These describe different greenhouse gas concentration trajectories adopted by the IPCC.

RCP 2.6
~1.0 C by 2100
Low emissions

Aggressive mitigation scenario. Global emissions peak around 2020 and decline steeply. Consistent with Paris Agreement targets.

RCP 4.5
~1.8 C by 2100
Moderate emissions

Emissions peak around 2040 then decline. Partial implementation of climate policies. Most commonly used as a "middle path" scenario.

RCP 8.5
~3.7 C by 2100
High emissions

Business-as-usual with continued fossil fuel reliance. Represents the upper end of warming trajectories. Critical for stress-testing long-lived assets.

Why all three scenarios matter

Buildings last 50-100 years. Using only optimistic scenarios (RCP 2.6) would understate risk if emissions reductions fall short. Using only pessimistic scenarios (RCP 8.5) may lead to over-engineering. The regulation expects a range to support robust decision-making.

The Maladaptation Principle

Appendix A explicitly prohibits maladaptation -- measures that address one climate risk while increasing another, or shift risk to other people, places, or ecosystems.

Examples of maladaptation:

Air conditioning overreliance

Increases energy demand, contributes to outdoor heat, and fails during power outages

Hard flood defences

May redirect floodwater to neighbouring properties or destroy riverine ecosystems

Excessive impervious surfaces

Reduces localised flooding but increases downstream runoff and heat absorption

Single-hazard focus

Sealing a building against heat without considering ventilation needs during heatwaves

This is why simulation matters. It is difficult to verify that an adaptation measure avoids maladaptation without modelling its effects on the full microclimate -- wind, temperature, humidity, and precipitation interactions at the building site.

Steps 2 and 4 Need Quantitative Data

The CRVA demands "highest available resolution" for climate risk assessment, and evidence that adaptation measures work. CFD simulation provides exactly this -- building-level wind, thermal, and microclimate analysis.