On 20 December 2021, the European Commission published its FAQs on reporting of Taxonomy-eligible economic activities and assets in accordance with the Taxonomy Regulation Article 8 Delegated Act.
The FAQs were accompanied by a guide from the Platform on Sustainable Finance (PSF) for in-scope firms that wish to make additional voluntary disclosures on the Taxonomy eligibility / alignment of their business (e.g. in respect of clients / counterparties that are non-EU entities or are otherwise not NFRD undertakings, or in respect of derivative trades that are expressly excluded from the mandatory disclosure obligations).
One very unhelpful development is that the Commission and the PSF have taken the view that firms must compile their Article 8 Delegated Act mandatory Taxonomy eligibility and alignment disclosures (including for reports published in 2022) on actual data – estimations and proxies are not allowed. Rather, the FAQs state that any estimations and proxies may only be disclosed on a voluntary basis, based on the recommendations in the PSF guide (and such voluntary disclosures must not contradict or be more prominent than the mandatory Article 8 Delegated Act disclosures).
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