In short
- There is no separate Taxonomy threshold. Article 8(1) borrows the Articles 19a and 29a test from the Accounting Directive.
- That borrowed test is now net turnover above EUR 450 million and an average above 1,000 employees, both in the same financial year.
- Out of scope does not mean out of the conversation, because a lender in scope has to fill in a Green Asset Ratio line about your building.
The EU Taxonomy carries no threshold of its own, which is exactly why this question is answered wrongly so often. Article 8(1) of Regulation (EU) 2020/852 binds any undertaking already obliged to publish non-financial information under Article 19a or Article 29a of Directive 2013/34/EU. So you run that test instead, and since Directive (EU) 2026/470 of 24 February 2026 it reads: net turnover above EUR 450 000 000 and an average above 1 000 employees during the financial year. Both. Miss either and you owe no Article 8 disclosure. You may still owe your bank an answer.
What is the test, stated exactly?
Four checks, in order, and the first one is the one people skip.
Check one. Look up the right instrument. Article 8(1) is a pointer, not a threshold. It says the duty falls on "any undertaking which is subject to an obligation to publish non-financial information pursuant to Article 19a or Article 29a of Directive 2013/34/EU". If you go looking inside Regulation (EU) 2020/852 for a turnover figure or a headcount figure you will not find one, because there is none to find.
Check two. Take your net turnover for the financial year. The figure has to exceed EUR 450 000 000. On a consolidated basis if you are a parent undertaking of a group, at entity level otherwise.
Check three. Take your average number of employees during the financial year. The figure has to exceed 1 000. Average across the year, not headcount on a single date.
Check four. Confirm both are true. The conjunction is "and". An undertaking with EUR 900 million of turnover and 400 people is out. An undertaking with 3 000 people and EUR 200 million of turnover is out. Only the intersection is in.
How do the outcomes actually land?
| Your position | Article 8 Taxonomy duty | What you will still be asked for |
|---|---|---|
| Above both figures | Yes. Publish turnover, CapEx and OpEx alignment | Everything below as well, from lenders and funds |
| Above turnover only | No | Energy evidence on financed assets |
| Above headcount only | No | Energy evidence on financed assets |
| Below both | No | Energy evidence on financed assets |
| Parent of a group, consolidated figures above both | Yes, on a consolidated basis | The same |
The middle three rows are where most of the European property market now sits. The large majority of owners, developers, funds and asset managers in this sector fall under one or both figures and have no direct Taxonomy reporting obligation at all.
Why did the answer change without the Taxonomy changing?
Because the pointer moved and the Regulation did not have to be touched.
Directive (EU) 2026/470, adopted on 24 February 2026 and published two days later, rewrote Articles 19a and 29a of the Accounting Directive. That rewrite is what set the EUR 450 000 000 and 1 000 employee pair. Article 8(1) of the Taxonomy Regulation reads the same words it always read, and now delivers a very different population. Anything you find written against the older Accounting Directive figures is describing a scope that no longer exists, whether it was published in 2023 or last month.
One qualification that matters if you are trying to fix a date. Directive (EU) 2026/470 is a directive, so national transposition determines when the narrower scope actually takes effect in a given Member State. Do not take a national start date from a vendor page, this one included. Check your own transposing law.
What do I do if the test says I am in?
You publish three ratios, and none of them is a tonnage.
Article 8 asks for the proportion of your turnover, your capital expenditure and your operating expenditure associated with taxonomy-aligned economic activities. Those come out of the financial statements you already prepare, split by activity. The classification half of the Regulation, the technical screening criteria, decides which activities count.
If your business is buildings, the relevant one is activity 7.7 of Annex I to Delegated Regulation (EU) 2021/2139, acquisition and ownership of buildings. For a building constructed before 31 December 2020, substantial contribution to climate change mitigation is demonstrated by an Energy Performance Certificate of at least class A, or by the building sitting within the top 15 percent of the national or regional stock measured as operational primary energy demand, shown with adequate evidence. A building constructed after that date is tested against the criteria for construction of new buildings in activity 7.1. A large non-residential building, meaning one with heating, combined heating and ventilation, air conditioning or combined air conditioning and ventilation rated above 290 kW, also has to be efficiently operated through energy performance monitoring and assessment.
Read that list again and notice what is absent. Certificate classes and kilowatt-hours. No emissions figure anywhere.
What do I do if the test says I am out?
You stop preparing an Article 8 disclosure and you start preparing an answer for whoever finances you.
This is the transmission mechanism nobody mentions. Credit institutions that are in scope publish a Green Asset Ratio, and the templates for it in Delegated Regulation (EU) 2021/2178, as amended by Delegated Regulation (EU) 2026/73, carry named lines for loans collateralised by residential immovable property, for building renovation loans, for housing financing under local government financing, and for collateral obtained by taking possession of residential and commercial immovable property. A bank cannot complete those lines out of its own records. It has to ask the borrower. That is why a landlord with no reporting duty of its own still receives a questionnaire, and why the questionnaire asks about energy performance rather than about carbon.
The practical response is unglamorous. Know which certificates you hold, know their classes and expiry, know the primary energy demand behind them, and know which of your assets cross 290 kW. If you are also being asked about emissions, that request is coming from somewhere else, and it is worth separating the two rather than commissioning one piece of work to answer both badly. Our note on which value chain questions you can decline is the place to start sorting requests by their legal source.
Is there anything in between?
Yes, and it arrived on 1 January 2026.
Delegated Regulation (EU) 2026/73 lets a non-financial undertaking omit assessing eligibility and alignment for activities that account for less than 10 percent of the denominator of the relevant turnover, capital expenditure or operating expenditure KPI. Financial undertakings, including credit institutions, asset managers, investment firms and insurers, get equivalent 10 percent derogations, the Green Asset Ratio included. So even inside scope, the assessment does not have to reach every corner of the business. Undertakings could still apply the pre-2026 rules for a financial year that started during 2025.
If you see that act cited as "(EU) 2026/76", the source is unreliable. That number does not exist. It is 2026/73.
Where does a carbon platform fit into this?
Honestly, at the edges rather than the centre, and it is worth saying so.
The Taxonomy question is answered from certificates, meter readings and the ledger. The carbon question is a separate deliverable with its own drivers, and it is the one our platform is built for, with over 20 000 spend-based and activity-based factors and entity management across sites, used by 5,000+ users. Both run off the same meters and the same landlord and tenant boundary, which is the real reason they get scoped together.
One limitation before you assume otherwise. A mid-market reviewer rated us 3.5 out of 5 on G2 in June 2026 and said that as a broader ESG and CSRD reporting platform this one is less complete, with no data source management feature and no decarbonisation target monitoring. Alignment ratios are not something we calculate. If that is the deliverable you need help with, CSRD consulting is the right door.
Sources: Regulation (EU) 2020/852 Article 8, Directive (EU) 2026/470 of 24 February 2026, Delegated Regulation (EU) 2021/2139 Annex I activity 7.7, Delegated Regulation (EU) 2021/2178, Delegated Regulation (EU) 2026/73, read against the Official Journal text. Verified 28 August 2026. National transposition of 2026/470 fixes the date the narrower scope applies in your country.
Facts on this page were last verified on 2026-09-17.
