Materiality thresholds, template overhaul, and DNSH chemistry criteria revised to cut compliance burden from 2026 on.
8th January, 2026 – Delegated Regulation (EU) 2026/73 amends three existing delegated acts under the EU Taxonomy Regulation (Regulation (EU) 2020/852): the Taxonomy Disclosure Delegated Regulation (2021/2178) which governs how companies report their alignment with the Taxonomy through key performance indicators, and the two Technical Screening Criteria Delegated Regulations covering climate objectives (2021/2139) and the remaining four environmental objectives (2023/2486).
These amendments pursue two distinct goals. In one hand, reducing the reporting burden on companies and financial institutions, and, on the other, clarifying the “do no significant harm” chemistry criteria that applies across all Taxonomy-eligible activities.
On reporting, the central change is the introduction of a 10% materiality threshold across all reporter categories. Non-financial companies may now omit assessing Taxonomy eligibility and alignment for economic activities that individually account for less than 10% of their turnover or capital expenditure denominator. A similar threshold applies to operational expenditure, with the additional option of omitting OpEx assessment entirely where it is not material to the business model. Financial undertakings, understanding asset managers, credit institutions, or insurers as such, receive equivalent thresholds for their respective KPIs, including the Green Asset Ratio, assets under management, financial guarantees, and fees and commission income.
Non-assessed activities must be separately disclosed and labelled as non-material rather than simply omitted from reporting. Financial undertakings that do not claim any Taxonomy-aligned activities may, until 31 December 2027, replace full KPI template disclosure with a standard opt-out statement in their management report. The Trading Book KPI and Fees and Commissions KPI for credit institutions are deferred until 2028. Derivatives, cash, on-demand interbank loans, goodwill, and commodities are excluded from KPI denominators for financial undertakings. Reporting templates across all annexes are significantly restructured and shortened, and the specific gas and nuclear disclosure templates (former Annex XII) are deleted and consolidated into general templates.
On DNSH chemistry criteria, the Regulation updates the generic pollution prevention and control criteria in Appendices C across both Technical Screening Criteria Delegated Regulations. The revised criteria explicitly permit the use of ozone-depleting substances where exemptions apply under Regulation (EU) 2024/590, and the use of restricted hazardous substances in electrical and electronic equipment where Directive 2011/65/EU exemptions apply. A previously applicable criterion requiring companies to screen all products and outputs for substances meeting SVHC hazard classification criteria under REACH is removed entirely, on the grounds that downstream supply chain data is not legally required to be provided for such substances in articles.
