
Don’t miss our content
SubscribeIntroduction
As part of the Omnibus I regulatory package, the European Commission (the "Commission") has included a proposal for amending certain aspects of the delegated acts on disclosure of information related to the taxonomy (2021/2178/EU), climate taxonomy (2021/2139/EU) and environmental taxonomy (2023/2486/EU), which it submitted to public consultation. See our Post | Omnibus I Proposal: amendment of environmental taxonomy.
On July 4, 2025, the Commission approved the reform of those delegated acts on taxonomy with the objective of:
- simplifying and clarifying the reporting obligations for companies; and
- adapting the technical criteria relating to the do-no-significant-harm (DNSH) principle.
Key aspects
Minimum materiality threshold: The materiality thresholds that exempt companies from carrying out an assessment of eligibility or compliance with the technical selection criteria for non-significant activities are maintained. This will enable companies to focus on the key performance indicators (KPIs) relating to the activities that are relevant for their business.
For these purposes, non-relevant activities are considered to be those whose turnover, investment in fixed assets (CapEx) or operating expenses (OpEx) represent less than 10% of the total and, in certain cases, less than 25% for OpEx.
Reduction and consolidation of reporting templates: the number of data points to be reported is significantly reduced, by consolidating templates and eliminating duplicates, particularly in relation to activities involving nuclear energy and fossil gas.
Exposures to counterparty undertakings that are not required to include sustainability information is excluded: Exposures to companies not subject to Directive 2013/34/EU (e.g., SMEs or foreign entities) are excluded, unless they report voluntarily or involve loans with known fund usage.
Revision of DNSH criteria regarding the use and presence of chemical products: the obligation to assess self-classified substances under the CLP Regulation is eliminated, limiting the assessment to substances with harmonized classifications and listed as candidates of very high concern (SVHC) under the REACH Regulation. This change represents one of the most relevant amendments compared to the draft issued in February 2025.
Clarification of the exemptions concerning the use of substances that deplete the ozone layer and hazardous substances present in electrical and electronic devices: the exemptions have been adapted to align with those established under Regulation on substances that deplete the ozone layer and under the RoHS Directive.
Postponement of specific KPIs for the finance sector: the requirement for financial companies to disclose KPIs relating to trading portfolios and fees and commission for services other than loans has been postponed until 2028.
Next steps
After approval by the Commission, the Delegated Act will be referred to the European Parliament and the Council for a four-month period of scrutiny (extendable for two additional months).
The measures under the Delegated Act will apply from January 1, 2026, and will cover the 2025 financial year.
Don’t miss our content
Subscribe