The European Commission Publishes a Delegated Act Amending the Taxonomy Disclosures, Climate and Environmental Delegated Acts

On 4 July 2025, the European Commission adopted a Delegated Act with measures to simplify the application of the EU Taxonomy by reducing the administrative burden for entities. The draft Delegated Act adopted by the Commission was published on 26 February 2025 for a four-week feedback period as part of the first Omnibus package.

Key impact on financial undertakings:

  • Financial undertakings are exempt from assessing Taxonomy eligibility and alignment of their financial assets if these account for less than 10% of loans and investments financing specific economic activities whose use of proceeds is known. These non-material assets must be reported separately as non-material exposures in the reporting templates.

 

  • Financial undertakings should report non-material activities separately at aggregated and individual levels. Undertakings should clearly state at individual level the sector of the economic activities that are considered as non-material to ensure transparency on those activities. For doing so, reporting undertakings may use the statistical classification of economic activities in the European Union (NACE) established by Regulation (EC) No 1893/2006.

 

  • The application of the reporting requirements related to the Trading Book KPI, and Fees and Commission KPI should be deferred until 2028.

 

  • The scope of the KPIs of financial undertakings should capture all financing and investments in undertakings that are subject to the reporting requirements laid down in Articles 19a and 29a of Directive 2013/34/EU, and in subsidiaries of parent-undertakings subject to Article 29a of that Directive given that those parent undertakings report individual sustainability information, including under the Taxonomy, about these subsidiaries.

 

  • Until the review of the reporting requirements and technical screening criteria laid down in the Climate Delegated Act and the Environmental Delegated Act is finalised, financial undertakings should be given the option not to use the templates laid down in the Annexes of the Disclosures Delegated Act. Instead, to ensure legal certainty, prevent risks of greenwashing, and observe proportionality, such undertakings should publish a standard statement in their management report to indicate that they do not claim that their economic activities are associated with environmentally sustainable activities as referred to in the Taxonomy Regulation.

Has Annex V of the Disclosures Delegated act, applicable to credit institutions, been amended?

Annex V has been slightly amended in two sections:

Section 1.1.2 adds:

The following assets shall be excluded from the numerator and the denominator of the GAR:

  1. financial assets held for trading;
  2. on-demand interbank loans;
  3. exposures to undertakings that are not obliged to publish non-financial information pursuant to Article 19a or 29a of Directive 2013/34/EU;
  4. derivatives;
  5. cash and cash-related assets;
  6. other categories of assets (such as goodwill, commodities, etc.).

 

Section 1.2.4:

Credit institutions shall disclose the following information:

  1. total trading during the disclosure period in Taxonomy-aligned instruments, including absolute purchases plus absolute sales of environmentally sustainable securities;
  2. total trading during the disclosure period of securities, including total absolute purchases plus total absolute sales of securities.

 

Is replaced with:

Credit institutions shall disclose quantitative information and KPIs that show to what extent the institution is trading with environmentally sustainable assets and to what extent it is contributing to promoting the trading of this type of assets.

 

The Delegated Act will be submitted to the European Parliament and the Council of the European Union for their scrutiny. The measures laid out in the Delegated Act will apply as of 1 January 2026 and will cover the 2025 financial year. Undertakings are given the option to apply the measures starting with the 2026 financial year if they find this more convenient.

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