Eurosif responds to ESMA consultation on Taxonomy Article 8 disclosures

On 30 July, Eurosif responded to ESMA’s consultation on simplifying Taxonomy reporting for non-financial undertakings and asset managers.

This input will inform the technical advice of the three European Supervisory Authorities (ESAs) to the European Commission, which plans to review the corresponding Taxonomy Disclosure Delegated Act under Article 8 of the Taxonomy Regulation by Q1 2027.

Why the ESMA consultation matters for responsible investors:

• As users of sustainability data, they rely on Taxonomy-alignment information disclosed by non-financial undertakings to assess portfolio alignment and report to their clients.
• As preparers of this information, some asset managers must comply with the Taxonomy Article 8 disclosure requirements and templates.

The consultation is still open until 12 August 2026 – Eurosif encourages asset managers to respond.

Eurosif's key messages:

• We acknowledge that broad OpEx Taxonomy reporting by non-financial undertakings aggregates diverse expenditure categories, making it difficult to interpret at portfolio level and limiting its usefulness due to inconsistent definitions, operational challenges and strong correlation with existing KPIs such as CapEx and turnover.
• OpEx KPI could therefore be simplified by narrowing its scope to clearly identifiable transition-related expenditures (such as R&D and green procurement). Aligning it more closely with accounting definitions would also be helpful.
• We caution against allowing financial undertakings to combine OpEx and CapEx in their Taxonomy disclosures. This would blur two indicators with distinct purposes: OpEx for current operating expenditure and CapEx for future-oriented investment reducing transparency and usefulness of the metric.
• Further cross-references between Taxonomy and ESRS sustainability reporting would improve consistency, reduce duplication and support more coherent disclosures across large EU companies.
• Any relief for non-financial undertakings on Taxonomy-alignment reporting should be limited to proportionate phase-ins and clearly justified.
• Separate reporting for Taxonomy enabling and transitional activities has limited practical usefulness for users as these activities are treated as environmentally sustainable under the current framework. It is also complex to disclose for asset managers. However, should the Taxonomy framework be expanded in the future to cover activities that are in transition, this information would be relevant for users.

Read our response here.