The First and Largest Set of Criteria
The Climate Delegated Act was published in December 2021 and applies from January 2022. It contains the technical screening criteria for the first two environmental objectives: climate change mitigation and climate change adaptation.
It covers approximately 90 economic activities across these sectors:
| Sector | Example Activities |
|---|---|
| Forestry | Afforestation, reforestation, forest management |
| Manufacturing | Cement, steel, aluminium, hydrogen, plastics, batteries |
| Energy | Solar, wind, hydropower, geothermal, gas-fired generation |
| Water & Waste | Water treatment, material recovery, methane capture from landfill |
| Transport | Passenger cars, freight transport, rail, cycling infrastructure |
| Construction & Real Estate | New buildings, renovation, acquisition of buildings |
| ICT | Data centres, data-driven climate solutions |
| Professional Services | R&D for climate solutions, engineering activities |
How to Read It
The delegated act is structured in two annexes:
- Annex I - Criteria for substantial contribution to climate change mitigation (plus DNSH criteria for the other five objectives)
- Annex II - Criteria for substantial contribution to climate change adaptation (plus DNSH criteria for the other five objectives)
Within each annex, activities are grouped by sector. For each activity, you get:
- Description - what the activity covers
- Substantial contribution criteria - the thresholds
- DNSH criteria - for each of the other five objectives
- Whether it is a transitional or enabling activity
The Nuclear and Gas Controversy
In July 2022, the Commission published the Complementary Climate Delegated Act (EU 2022/1214), adding specific nuclear energy and natural gas activities under strict conditions.
Nuclear power qualifies if:
- It meets the latest nuclear safety standards
- Spent fuel management and decommissioning plans are in place and funded
- It is in a country with a radioactive waste disposal facility operational by 2050
Natural gas qualifies if:
- It replaces coal or oil-fired generation
- Lifecycle emissions are below 100g CO2e/kWh, OR direct emissions are below 270g CO2e/kWh (declining over time)
- The facility is built to switch to renewable or low-carbon gases by 2035
The inclusion of nuclear and gas was politically controversial and faced legal challenges. Companies reporting taxonomy-aligned nuclear or gas activities must disclose them separately in their taxonomy reporting templates. Investors who disagree with these inclusions can screen them out using this separate disclosure.
Key Takeaways
- 1The Climate Delegated Act covers roughly 90 activities across 8 sectors for climate mitigation and adaptation
- 2Each activity has specific substantial contribution thresholds plus DNSH criteria for all other objectives
- 3Nuclear and gas were added in 2022 under strict conditions and must be disclosed separately in reporting templates
- 4The criteria are structured in Annex I (mitigation) and Annex II (adaptation) - look up your activity by sector