Partner
Auditor, CPA (U.S.), Head of Accounting, Reporting & Process Advisory
EU Taxonomy Update 02/2026: The Taxonomy in the Reform Process
- The fourth Notice provides interpretive guidance on Delegated Regulation (EU) 2026/73.
- The consultation on the revision of the Climate and Environmental Delegated Acts has concluded.
- Final regulations expected for summer 2026.
- The EU Taxonomy reform continues – adjustments to reporting obligations have been announced.
The reform of the EU Taxonomy continues to gain momentum: With the finalized Commission FAQ Notice and the completed consultation on the revision of the Climate and Environmental Delegated Acts, companies subject to reporting requirements face specific interpretive questions for reporting in the 2026 and 2027 financial years.
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Background
With Delegated Regulation (EU) 2026/73, published in the Official Journal of the EU on January 8, 2026, simplified reporting obligations for the EU Taxonomy have come into force. Core elements include the newly introduced materiality principle, the streamlined reporting template structure, and adjustments to the DNSH criteria. For the 2025 financial year, there was an option for early adoption; from the 2026 financial year, the new requirements are mandatory. On this basis, further developments have since emerged that are of immediate relevance to companies subject to reporting requirements.
Fourth Commission Notice: Interpretive Guidance for Practical Application
On April 30, 2026, the FAQs on the new Delegated Regulation were published in the Official Journal of the EU as the so-called “fourth Commission Notice” (C/2026/2558). The Notice replaces the Draft Commission Notice of December 17, 2025, and thus provides the Commission’s official interpretation of the new reporting obligations.
The document comprises 17 questions and answers and addresses the following focal areas:
- Questions on the initial application of Delegated Regulation (EU) 2026/73 to simplify reporting obligations
- Interpretive questions on the newly introduced materiality principle, in particular on the application of the 10% threshold per KPI and on the delimitation of material economic activities in relation to segment reporting under IFRS 8
The Notice does not introduce new requirements and does not expand existing rights or obligations. The FAQ documents are not legally binding – they reflect the EU Commission’s interpretation of the underlying legislation. Nevertheless, it is recommended that companies subject to reporting requirements consult the Notice for open interpretive questions, as it provides important guidance for practical application.
Revision of the Climate and Environmental Delegated Acts
On March 17, 2026, the European Commission launched a public consultation on two draft regulations intended to simplify and adapt the technical screening criteria of the Climate and Environmental Delegated Acts (Delegated Regulation (EU) 2021/2139 and Delegated Regulation (EU) 2023/2486). The consultation period ended on April 14, 2026. The adoption of the final legal acts is planned for summer 2026; following a standard objection period by Parliament and Council, application is expected from the 2027 financial year.
The draft amendments affect a large number of the economic activities contained in both legal acts – including forestry, manufacturing, energy, transport, construction and real estate, as well as water and waste management.
Overall, the drafts focus on:
- Simplification and clarification of the technical screening criteria based on practical experience and feedback from reporting
- Facilitation of the provision of evidence, in particular through greater reliance on existing Union law requirements
In parallel, the EU Commission has commissioned European financial supervisory authorities (EBA, ESMA, and EIOPA) to develop technical guidelines for taxonomy reporting by October 2026. These are intended to serve as the basis for a further revision of the Delegated Regulation on reporting obligations. The ongoing reform of the Taxonomy is therefore not yet complete.
Outlook
Companies that exercised their option for the 2025 financial year and still reported according to the previous system are now facing the initial application of the new reporting obligations: From the 2026 financial year, Delegated Regulation (EU) 2026/73 is mandatory. The remaining time should be used to fully integrate the new requirements – in particular the materiality principle, the adapted reporting template structure, and the revised DNSH criteria – into internal reporting processes.
The reform process of the EU Taxonomy is not concluded with these steps. The final revised Delegated Regulations for the Climate and Environmental Delegated Acts are expected for summer 2026. Furthermore, the EU Commission has signaled that the Delegated Regulation on reporting obligations is also to be revised again based on the guidelines to be developed by the European Supervisory Authorities by October 2026.
Companies subject to reporting requirements should make targeted use of the remaining months of 2026: The final regulations for the revision of the Climate and Environmental Delegated Acts expected for summer 2026 should be promptly reviewed for their impact on the company’s own taxonomy reporting from the 2027 financial year. It is recommended to analyze existing processes, data foundations, and internal control systems early for any need for adjustment and to coordinate this with the auditor.