EU Taxonomy in Transition: Commission Plans Extensive Adjustments to Technical Screening Criteria

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The EU Taxonomy Remains in Motion

The EU Taxonomy continues to undergo a comprehensive revision process. After the European Commission already made significant changes to the requirements for Taxonomy reporting by adjusting the reporting obligations (Delegated Regulation (EU) 2026/73), the focus is now on the technical screening criteria (TSC). These criteria determine the conditions under which an economic activity makes a substantial contribution to one or more of the six environmental objectives of the EU Taxonomy while causing no significant harm to the other environmental objectives (“Do No Significant Harm”, DNSH) and can thus become Taxonomy-aligned.

On March 17, 2026, the European Commission published two draft Delegated Acts to revise the technical screening criteria of the Climate and Environmental Delegated Acts. The goal of the planned changes is to make the criteria clearer and more practical and to link existing requirements more closely with established regulatory standards. At the same time, the existing level of environmental ambition of the EU Taxonomy is to be fundamentally maintained. The current drafts may lead to noticeable changes for companies, particularly when assessing the Taxonomy-alignment of their economic activities.

Timeline of Current Developments

2025

• Review and simplification of the EU Taxonomy
• Public consultation and technical workshops to review the technical screening criteria

January 2026

• Publication of Delegated Regulation (EU) 2026/73
• Simplification, particularly of reporting obligations and individual DNSH criteria

March 2026

• Publication of drafts for the comprehensive revision of the technical screening criteria
• Affected: Delegated Regulation (EU) 2021/2139 on climate and environmental targets and Delegated Regulation (EU) 2023/2486 on the other four environmental objectives

Q3 2026

• Planned adoption of the revised Delegated Acts
• Followed by a four-month scrutiny period by the European Parliament and the Council

Parallel 2026/2027

• Further review of the EU Taxonomy
• Technical recommendations from the European supervisory authorities (EBA, ESMA, EIOPA) as a possible basis for further adjustment

Changes in the Course of the Revision of Technical Screening Criteria

The primary focus of the planned adjustments is the simplification and clarification of the technical screening criteria, better applicability in practice, and stronger integration with existing regulatory requirements. Furthermore, individual economic activities and technical criteria are being adjusted or redefined. Selected changes are presented below.

Adjustments to the DNSH Criteria “Pollution Prevention and Control”

The planned changes to the DNSH criteria for pollution prevention and control (Appendix C) aim in particular to align the requirements more closely with existing mechanisms of European chemicals law. For example, for certain substance groups, direct reference is made to requirements of the REACH Regulation and other relevant EU regulations. At the same time, the conditions for permissible exceptions are more clearly defined, thereby facilitating practical application.

For companies, this potentially means a significant reduction in the additional documentation effort during the assessment of DNSH criteria, especially for companies already subject to extensive environmental law requirements. However, the decisive factor will be the extent to which existing permits and evidence cover the specific technical requirements of the Taxonomy.

Adjustments to the DNSH Criteria “Climate Change Adaptation”

The requirements of the DNSH criteria for climate change adaptation (Appendix A) are also to be changed and designed to be more risk-based in the future. For this purpose, a multi-stage procedure is introduced within the Delegated Regulation: First, a screening must be carried out to determine whether climate-related hazards can significantly affect the economic activity in question during its expected lifespan. A detailed climate risk assessment must only be carried out if a potentially significant influence is identified.

For companies, this means a more targeted and proportionate assessment of climate risks. It is made clear that the climate risk assessment refers explicitly to the specific economic activity whose Taxonomy-alignment is being checked. Furthermore, a comprehensive climate risk analysis is not required across the board, but is only carried out if a potentially significant climate risk for the activity in question is identified in the upstream screening. For the implementation of the screening, the draft also refers to suitable instruments at the EU level as examples.

Revision of the Technical Screening Criteria for Substantial Contribution

A key component of the planned changes is the revision of the technical screening criteria for the substantial contribution to environmental objectives. The adjustments affect a large part of the existing economic activities in the Climate and Environmental Delegated Acts and extend across all six environmental objectives of the EU Taxonomy. The changes range from the adjustment of individual technical requirements to expanded options for providing evidence. Particularly extensive changes are planned in the areas of manufacturing, energy, transport, as well as construction and real estate.

Numerous technical screening criteria are also being adjusted within the environmental objective of climate change mitigation. For example, in activity category 7.1 “Construction of new buildings,” the previous requirement is replaced by criteria for zero-emission buildings. In activity category 7.3 “Installation, maintenance and repair of energy efficiency equipment,” the acquisition, rental, and leasing of corresponding equipment are now explicitly included. For activity category 7.7 “Acquisition and ownership of buildings,” a third option for providing evidence is added for existing buildings.

What Does This Mean for Companies?

The planned changes may also necessitate adjustments for companies that have already established Taxonomy assessments. In particular, three areas should be reviewed early on:

Update Taxonomy Check: Companies should check whether their activities previously classified as Taxonomy-eligible or Taxonomy-aligned are still covered under the new activity descriptions and technical screening criteria and meet the respective requirements.

Review Evidence Processes: Particularly within the framework of the DNSH criteria, it should be analyzed whether existing permits, environmental management systems, monitoring reports, or other regulatory evidence can be used for Taxonomy verification in the future.

Adapt Data Basis and Responsibilities: Changes to the technical screening criteria can also change the required data points, evidence, and internal responsibilities. Companies should therefore check early on whether existing processes and responsibilities remain suitable or need to be adapted.