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Who Must Report?

The EU Taxonomy reporting scope follows the CSRD perimeter for non-financial companies and adds sector-specific rules for financial institutions.

Core size thresholds

Large undertakings generally fall into scope when they meet at least two of the three core size tests.

> 250

Employees

Average number of employees during the financial year

> EUR 50M

Net turnover

Annual net turnover

> EUR 25M

Total assets

Balance-sheet total

The February 2025 Omnibus proposal would narrow mandatory taxonomy reporting for smaller companies, but the underlying size logic remains relevant for scoping discussions.

The three main KPIs

Non-financial companies report taxonomy-eligible and taxonomy-aligned turnover, CAPEX, and OPEX.

Turnover

Share of net turnover associated with taxonomy-relevant activities.

Taxonomy-aligned turnover / total net turnover

CAPEX

Share of capital expenditure linked to taxonomy-relevant assets, projects, or transition plans.

Taxonomy-aligned CAPEX / total CAPEX

OPEX

Share of eligible operating expenditure linked to taxonomy-relevant activity.

Taxonomy-aligned OPEX / taxonomy-eligible OPEX

Reporting by entity type

Different categories of undertakings face different disclosure obligations under the Taxonomy.

Large non-financial companies

CSRD

Large undertakings disclose turnover, CAPEX, and OPEX with eligibility and alignment breakdowns.

  • Per-objective eligibility and alignment reporting
  • Standardized KPI templates
  • Separate treatment of enabling and transitional activities

Banks and credit institutions

CRR

Banks report the Green Asset Ratio and related taxonomy portfolio indicators.

  • GAR based on banking-book exposures
  • Objective and sector breakdowns
  • Treatment rules for excluded exposures

Insurers

Solvency II

Insurance undertakings report taxonomy alignment for investment and certain underwriting exposures.

  • Investment alignment disclosures
  • Climate-relevant underwriting indicators

Asset managers

SFDR

Asset managers disclose taxonomy alignment at entity and product level.

  • Product-level alignment for relevant funds
  • Linkage to SFDR reporting

Phase-in timetable

Reporting obligations have expanded in several waves.

Wave 12024 for FY 2023

Large public-interest entities previously in scope of the NFRD

Initial first-wave reporters
Wave 22025 for FY 2024

Additional large undertakings meeting the standard CSRD size criteria

Broader large-company population
Wave 32026 for FY 2025

Listed SMEs and certain smaller financial undertakings under the phased schedule

Later phase-in entities
Omnibus proposalProposed from 2025-2026

Simplified or voluntary treatment for some smaller undertakings

Subject to adoption

Eligibility versus alignment

Eligibility asks whether the activity is covered by the delegated acts. Alignment asks whether the activity also meets the four substantive conditions.

Reporting both numbers helps users distinguish scope from real environmental performance.

Explore the full framework

Understand the regulation, the objectives, and the technical criteria that sit behind the reporting obligation.