On 7 November 2025, the European Commission published a call for evidence on proposals to amend the European Union’s Taxonomy legislation. In particular, the call is in relation to two delegated regulations amending the Taxonomy Climate Delegated Act ((EU) 2021/2139, the “Taxonomy Climate Delegated Act”) and the Taxonomy Environmental Delegated Act ((EU) 2023/2486, the “Taxonomy Environmental Delegated Act”) (the “Call for Evidence”). The document is accessible via Commission webpages relating to the Taxonomy Climate Delegated Act and the Taxonomy Environmental Delegated Act.

Political context

The Call for Evidence sits within the European Commission’s broader simplification agenda to cut red tape and reflects the commitment to reduce reporting burdens for companies and support sustainable finance through clearer and more proportionate rules. It also responds to the Commission’s obligation under the EU Taxonomy Regulation (Regulation (EU) 2020/852) to regularly review and, where appropriate, amend the technical screening criteria.

Aim of initiative

The European Commission has noted that experience from the initial application indicates that some technical screening criteria in the Taxonomy Climate Delegated Act and the Taxonomy Environmental Delegated Act have proved complex or difficult to evidence in practice.

The European Commission is therefore of the view that, without EU-level intervention, these issues are likely to persist or intensify; the risk is not only administrative — if the framework is seen as impractical or insufficiently robust, it could, in their view, undermine confidence in the EU’s wider sustainable-finance agenda.

The European Commission is therefore collecting further evidence through targeted consultations, feedback to this Call for Evidence and continued engagement with stakeholders involved in the day-to-day application of the EU Taxonomy Regulation.

Next steps

The deadline for providing comments is 5 December 2025, so there is only a short window to have your say. The feedback provided will then feed into the revision of the Taxonomy Climate Delegated Act and Taxonomy Environmental Delegated Act.

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.

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Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in…

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in the UK, as well as trading on UK and EU markets.

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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.

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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.

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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.

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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.