On 4 July 2025, the European Commission adopted a regulation (the “Delegated Regulation”) aimed at streamlining the European Union’s Taxonomy Regulation (the “Taxonomy Regulation”). These reforms are intended to ease administrative burdens on EU companies and strengthen the EU’s global competitiveness, while maintaining the integrity of its core climate and environmental objectives.

The Taxonomy Regulation, in force since 2020 and applicable to reporting requirements from 2022, provides a standardized framework for assessing the sustainability of economic activities for both financial and non‑financial companies. Its aims are to create a common classification system for environmentally sustainable economic activities and:

  • guide investments toward activities that significantly contribute to the EU’s environmental objectives, such as climate change mitigation and adaptation;
  • support the European Green Deal by helping the EU meet its climate and energy targets for 2030 and achieve climate neutrality by 2050;
  • provide clarity and transparency for investors, companies and policymakers by defining what qualifies as “environmentally sustainable”;
  • prevent greenwashing by setting clear criteria and technical screening standards; and
  • promote consistency across the EU financial system, reducing market fragmentation and enhancing comparability of sustainability‑related disclosures.

However, there has been both technical and political criticism of the Taxonomy Regulation, including around its complexity and usability issues. As a result, the European Commission’s Delegated Regulation is aimed to remedy some of these challenges, as follows.

Key simplification measures introduced include:

Materiality Thresholds Introduced

Financial and non‑financial companies will be exempt from assessing taxonomy eligibility and alignment for economic activities deemed non‑material. For non‑financial companies, this applies where activities represent less than 10% of a company’s total revenue, capital expenditure or operational expenditure.

By reducing this administrative burden, companies can focus on reporting and financing of their core business activities, including how this may contribute towards their transition efforts.

Streamlined Reporting Templates

The number of data points required in taxonomy reporting templates will be reduced by 64% for non‑financial companies and 89% for financial companies.

Simplified KPIs for Financial Companies

Financial institutions will benefit from simplified key performance indicators (such as the Green Asset Ratio) and may opt out of detailed taxonomy KPI reporting for two years.

“Do No Significant Harm” Criteria

The criteria for “Do No Significant Harm” relating to pollution prevention and control related to the use and presence of chemicals are simplified in the new Delegated Regulation.

When does this apply?

The Delegated Regulation will now be submitted to the European Parliament and the Council of the EU for review. It is expected to enter into force 20 days following its publication in the Official Journal, and will apply from 1 January 2026 and will cover the 2025 financial year. However, undertakings may choose to apply the new measures early, starting with the 2026 financial year.

For further information, please reach out to ukreg@proskauer.com.

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Photo of John Verwey John Verwey

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge…

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge fund managers as well as institutional managers and advisers, on all aspects of the UK and EU regulatory regimes.

Another key area of focus is advising clients in the financial services sector on mergers and acquisitions, re-organisations and associated regulatory approvals.

John represents a variety of clients that range from small start-up fund managers to established global fund advisers and managers. In The Legal 500, John is noted as “an all-rounder who gets into the details and manages client expectations on navigating tricky regulatory requirements”.

Photo of Rachel Lowe Rachel Lowe

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on…

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Rachel has also supported with EU MiFID and AIFMD sustainability updates for clients, including from a governance and organizational perspective, as well as providing drafting and training support. She also advises on the Corporate Sustainability Reporting Directive (CSRD), including analysis of its applicability for large international group structures.

From a UK perspective, Rachel supports clients with the TCFD-related requirements in the Financial Conduct Authority’s ESG Sourcebook and is increasingly engaged on the UK’s Sustainability Disclosure Requirements (SDR).

More broadly, Rachel has worked with litigation colleagues to assist clients with understanding and mitigating greenwashing-related legal and regulatory risk.

Photo of Sulaiman Malik Sulaiman Malik

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers…

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers, as well as banks, FinTechs, broker-dealers and governments.

Prior to joining Proskauer, Sulaiman trained at Simmons & Simmons in London, where he was seconded to Brevan Howard. He has also spent time at the UK’s Ministry of Justice and as an adviser to the Mayor of Brisbane, in Australia.

Sulaiman is a passionate advocate for diversity and inclusion. He previously worked at Rare, a market-leading diversity consultancy, and provides pro bono legal advice to a range of community and civil rights organizations.

Photo of Michael Singh Michael Singh

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms…

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms, investment managers, FinTech companies and wealth management businesses.

He is dual-qualified as a German lawyer (“Rechtsanwalt”) and Solicitor of England and Wales and previously was in-house counsel at Deutsche Bank.