The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) published the results of its second focused examination of EU Taxonomy Regulation Article 8 reporting by non-financial issuers for the 2024 reporting year. The review finds broad adoption of the mandated disclosure templates and improved qualitative explanations, but highlights recurring weaknesses that affect the traceability and reliability of Taxonomy key performance indicators (KPIs), particularly around CapEx denominator calculations, financial statement referencing, year-on-year analysis and double-counting controls. The sample comprised 20 supervised non-financial issuers with more than 10% Taxonomy-eligible turnover or more than 10% Taxonomy-eligible CapEx, covering 82 eligible and 40 aligned activities in total. All issuers used the Annex II templates in the Taxonomy Disclosures Delegated Act, and 90% provided detailed explanations of compliance with technical screening criteria, do no significant harm criteria and minimum safeguards, while 20% showed deficiencies in describing eligible and aligned activities. The CSSF identified gaps in traceability where some issuers did not reference relevant financial statement line items for turnover and CapEx, and found that only 50% provided meaningful explanations for year-on-year KPI movements and only 50% documented concrete measures to prevent double counting. CapEx denominator calculation was a key recurring issue, with 40% of issuers showing deficiencies driven mainly by omissions of right-of-use assets, intangible assets and additions from business combinations; only one issuer explicitly reported Taxonomy-aligned investments allocated to a CapEx plan. The report points to ongoing and forthcoming EU-level changes, including the European Commission’s draft Omnibus Simplification Package and planned amendments to the Taxonomy Delegated Acts. A public consultation on amendments to the Taxonomy Disclosures Delegated Act and the Climate and Environmental Delegated Acts closed on 26 March 2025, with formal adoption expected in the second half of 2025 and entry into force stated as 1 January 2026.
Luxembourg Commission de Surveillance du Secteur Financier 2025-07-01
Luxembourg Commission de Surveillance du Secteur Financier publishes review of EU Taxonomy disclosures and flags recurring CapEx denominator errors
The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) released findings from its second examination of EU Taxonomy Regulation Article 8 reporting by non-financial issuers for 2024. The review noted broad adoption of disclosure templates and improved qualitative explanations but identified weaknesses in KPI traceability and reliability, particularly in CapEx calculations and financial statement referencing. The report also highlighted ongoing EU-level changes, including the European Commission’s draft Omnibus Simplification Package and amendments to the Taxonomy Delegated Acts.