EU Taxonomy alignment · Regulation (EU) 2020/852
Your Taxonomy alignment, measured activity by activity and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
EU Taxonomy alignment · Regulation (EU) 2020/852
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2020/852 of 18 June 2020 (Taxonomy), and its Climate and Environmental Delegated Acts assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, a level, a level above it, and the action linking the two, that turns a finding into a trajectory.
Is evidence for the water and biodiversity DNSH criteria collected and tracked by site?
- N1
No organised collection. The material exists in site permitting files, with no link to the Taxonomy exercise.
- N2
Collection happens close to disclosure deadlines, by directly contacting a few sites. Format and level of detail vary.
- N3
A list of expected evidence per activity and per site is circulated, collection follows an annual calendar, and files are archived in one place.
- N4
Collection is built into periodic HSE reporting, each piece of evidence is mapped to a criterion and an owner, and gaps are tracked as findings.
- N5
Evidence is refreshed every time the delegated acts or operating permits change, with a documented review of changes and their effect on published alignment.
Action to move from level 2 to level 3
Draw up the list of DNSH evidence expected per eligible activity, send it to site environment managers with a deadline tied to the annual HSE review, and centralise the files in a single space referenced by criterion.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2020/852 sets out six environmental objectives: climate change mitigation, adaptation, water and marine resources, circular economy, pollution prevention, and biodiversity and ecosystems. An activity is aligned if it substantially contributes to one of these objectives against the technical screening criteria set by the delegated acts, causes no significant harm to any of the other five (DNSH criteria), and complies with minimum social and governance safeguards. Alignment is disclosed activity by activity, through turnover, CapEx and OpEx indicators.
In the mining and extractive industry, steering this exercise runs up against the structure of the text itself. Extractive activities are not all listed as such in the delegated acts, whereas processing, tailings recovery, on-site power generation or rehabilitation activities may be. Three questions come up repeatedly: which activities in the portfolio are eligible, and on what documented basis? Who produces the DNSH evidence on water, pollution and biodiversity, site by site? How do you split turnover and CapEx between eligible and non-eligible activities without rebuilding the management accounts every year?
One common confusion is worth clearing up: the Taxonomy does not classify companies, it classifies activities. A non-eligible activity is not a poorly managed one, and a low alignment rate can simply reflect the nature of the portfolio rather than a management failing. Alongside this, Regulation 2024/1252 on critical raw materials and sustainability reporting requirements are shifting attention towards the quality of the underlying data: traceability of scope, consistency between published indicators and site environmental data, and the ability to document minimum safeguards across the whole chain.
Checking published disclosures asks one thing: is the activity aligned, yes or no. A maturity assessment asks something else entirely: what level of control do your eligibility, DNSH evidence, financial allocation and governance processes actually sit at, and what precise action moves each one up to the next level. It is this view that lets you plan several reporting cycles ahead, and steer investment rather than simply reacting to the disclosure calendar.
In Datamensio, the framework is ready to use. You can adapt it to your portfolio of activities: the AI adjusts the themes, questions and levels, or builds a version by site, subsidiary or commodity family from your own documents.
Reference standard: Regulation (EU) 2020/852 of 18 June 2020 (Taxonomy), and its Climate and Environmental Delegated Acts
The themes assessed
Activity mapping and eligibility
Inventory of economic activities carried out, mapping to delegated act descriptions, NACE codes used, treatment of enabling and transitional activities, documentation of activities deemed non-eligible.
Substantial contribution
Identification of the environmental objective targeted per activity, application of technical screening criteria, thresholds and reference values used, supporting technical evidence and associated measures.
DNSH criteria: climate and water
Climate vulnerability analysis and adaptation measures, management of withdrawals and discharges, alignment with the Water Framework Directive and groundwater, monitoring of affected water bodies.
DNSH criteria: pollution, waste and circularity
Prevention of air and soil pollution, management of extractive waste and tailings, recovery of waste rock, substances subject to REACH and CLP, mercury restrictions.
DNSH criteria: biodiversity and land use
Impact assessments on Natura 2000 sites and habitats, avoidance and offset measures, rehabilitation and restoration plans, post-mining monitoring.
Minimum safeguards
Due diligence arrangements, alignment with OECD and UN guiding principles, labour rights and health and safety, anti-corruption, tax, competition.
Financial indicators and allocation
Method for mapping turnover, CapEx and OpEx to activities, consolidation scope, treatment of CapEx plans, prevention of double counting.
Data, traceability and systems
Data sources per site, consistency checks, audit trail for published figures, collection frequency, tooling and data entry responsibilities.
Governance and disclosure
Roles and internal sign-off, management review, alignment with sustainability reporting, preparation for external assurance, communication to investors and lenders.
Multi-year trajectory and steering
Alignment target per activity, associated investment plans, milestones, monitoring indicators, annual review in light of changes to the delegated acts.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can the EU Taxonomy be certified?
No. Regulation 2020/852 is a classification system underpinning disclosed information, which may be subject to external assurance. No body issues an alignment certificate. The assessment measures the maturity of your processes and prepares you for assurance, it does not replace it.
What is the difference between checking published disclosures and a maturity assessment?
Checking disclosures focuses on an outcome: does the activity meet the technical criteria, are the figures justified or not. The assessment places your eligibility, evidence and financial allocation processes on a progressive scale and shows the trajectory. The two complement each other.
Is the framework relevant if few of our activities are eligible?
Yes. Documenting why an activity is not eligible is part of the exercise, and it is often the weakest point. The assessment covers activity mapping, data quality and minimum safeguards, which remain useful whatever the alignment rate.
How long does the assessment take?
The short version takes 20 to 30 minutes for a sustainability or finance manager to complete. The full version, run collaboratively with sites, finance and HSE teams, generally spans one to two weeks, most of the time going into data collection.
Can the framework be adapted to our activity portfolio?
Yes. Themes, questions and levels can all be modified, and the AI builds a version by activity, site or subsidiary from your documents. You can also add your own internal trajectory criteria.
How does this assessment fit with our other regulatory assessments?
The DNSH criteria refer back to texts you are already assessing: extractive waste, water, air quality, Natura 2000, REACH, emissions allowances. Cross-cutting roadmaps consolidate several assessments and avoid duplicating shared actions.
Can sites be compared with each other and progress tracked?
Yes. Industrial audits allow several business units to be assessed against the same framework, scores compared theme by theme, and progress benchmarked against previous exercises. The AI groups gaps into a prioritised roadmap.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.