EU Taxonomy and Morocco’s Green Taxonomy: A Supplier’s Guide

What is the EU taxonomy, and which text is the reference?

The EU taxonomy is a classification system that defines which economic activities can be considered environmentally sustainable. Its legal basis is Regulation (EU) 2020/852 of 18 June 2020, in force since 12 July 2020; the detailed criteria sit in Commission delegated regulations.

The regulation classifies activities, not companies. Under Article 3, an economic activity is environmentally sustainable if it meets four cumulative conditions:

1. it contributes substantially to one or more of the six environmental objectives in Article 9;
2. it does no significant harm to any of those objectives (the ‘DNSH’ principle, defined in Article 17);
3. it is carried out in compliance with minimum safeguards (Article 18): procedures aligned with the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the eight fundamental ILO conventions and the International Bill of Human Rights;
4. it complies with the technical screening criteria set by the Commission.

The six objectives are climate change mitigation, climate change adaptation, sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems.

Two categories matter for industrial suppliers. Enabling activities (Article 16) directly enable other activities to contribute substantially to an objective; an equipment manufacturer may fall into this category. Transitional activities (Article 10(2)) have no technologically and economically feasible low-carbon alternative yet; they can count as contributing to mitigation if their emissions match the best performance in the sector and they do not lock in carbon-intensive assets.

The Commission’s online EU Taxonomy Navigator, including the Taxonomy Compass, lists the activities and their criteria.

Who must disclose taxonomy information, and what changed on 1 January 2026?

Only companies within the sustainability reporting scope of the EU Accounting Directive disclose taxonomy KPIs; since 1 January 2026, Delegated Regulation (EU) 2026/73 has significantly reduced what they must assess. A Moroccan company has no direct disclosure obligation.

What Article 8 requires

Article 8 of Regulation (EU) 2020/852 requires undertakings subject to Articles 19a or 29a of Directive 2013/34/EU to disclose how far their activities are associated with sustainable activities. A non-financial undertaking reports three KPIs: the share of its turnover, capital expenditure (CapEx) and operating expenditure (OpEx) associated with such activities.

Fewer companies are now in scope. Directive (EU) 2026/470 (Omnibus I) limits sustainability reporting to undertakings with net turnover above EUR 450 million and more than 1,000 employees on average. In its amended wording, the limited assurance opinion on the sustainability report also covers compliance with the Article 8 disclosure requirements. Our ESG questionnaires, CSRD and VSME page sets out the post-Omnibus CSRD scope.

What Delegated Regulation (EU) 2026/73 changed

Delegated Regulation (EU) 2026/73 of 4 July 2025, published in the Official Journal on 8 January 2026 and applicable since 1 January 2026, brings four changes that matter to a supplier (EUR-Lex, read on 11 November 2026):

• A 10% materiality threshold. A non-financial undertaking does not have to assess the eligibility or alignment of activities whose combined turnover is below 10% of the KPI denominator; the same rule applies to CapEx.
• Lighter OpEx reporting. If opex is not material to its business model, the undertaking can skip the assessment altogether, provided it discloses the total and explains why; otherwise the 10% threshold applies. Exempted amounts are reported separately as ‘non-material’.
• Fewer questions about substances. The generic DNSH criteria that required companies to track substances in certain hazard classes across all products were deleted, because suppliers have no legal duty to disclose those substances when they are present in an article (recital 19).
• Banks refocused. A financial undertaking now excludes from its KPI denominators its exposures to companies that are not subject to sustainability reporting and do not belong to a group that is. It may include them again if the company voluntarily reports KPIs under the annexes of Delegated Regulation (EU) 2021/2178, or if the use of proceeds is known.

For financial years starting in 2025, companies could still apply the delegated acts as they stood on 31 December 2025. The broader revision of the technical screening criteria, put to consultation from 17 March to 14 April 2026 and announced for adoption by the summer, was still shown as not adopted on the Commission page on 11 November 2026: the current criteria still apply.

Why does an EU customer or bank send you taxonomy questions?

Because the alignment of their own activity sometimes depends on what you sell them, or on what you do with their money. The taxonomy imposes nothing on you directly; it explains some of the questions in your questionnaires, specifications or credit files.

Three situations come up again and again in our work with Moroccan exporters:

• Your customer reports an aligned activity. A European manufacturer that wants to count equipment, an installation or a production line in its aligned turnover or CapEx must prove compliance with the technical screening and DNSH criteria. If a component or service you supply is part of that calculation, it will ask you for performance, emissions or compliance data.
• You are a subsidiary of an EU group. A Moroccan subsidiary of a group that publishes a consolidated sustainability report falls within the group’s KPIs: its sales, investments and expenses are classified like the rest of the group.
• You borrow from an EU bank. Since Delegated Regulation (EU) 2026/73, a company outside the CSRD drops out of its bank’s KPI denominator. The bank will only ask taxonomy questions for a financing whose use of proceeds is known (a project, an asset), if you report KPIs voluntarily, or if you belong to an in-scope group.

A taxonomy question is not always a CSRD question within the value-chain cap. For its CSRD report, an in-scope customer can only require a supplier with 1,000 employees or fewer to provide the information in Annex II of Delegated Regulation (EU) 2026/1560; a request for technical data on equipment is more often a contractual matter. Annex II is explained in our VSME standard guide.

What is Morocco’s green taxonomy, and where does it stand?

The Green Finance Taxonomy of Morocco (TFVM in French) is a national reference framework that classifies economic activities as green on the basis of scientific and technical criteria. As of 11 November 2026 it is a draft: the public consultation opened on 10 July 2026 closed on 31 July 2026, and no final version is published on the official websites we consulted.

Who is preparing it, and why?

According to the Ministry of Economy and Finance press release of 10 July 2026, also published by the AMMC (the Moroccan capital markets authority), the consultation is run jointly by the Ministry of Economy and Finance, Bank Al-Maghrib (the central bank), the AMMC, ACAPS (the insurance and pension supervisor) and the Ministry of Energy Transition and Sustainable Development, with technical support from the World Bank and the Agence Française de Développement group. It is part of Morocco’s 2030 climate finance development strategy, its updated nationally determined contribution (NDC 3.0) and its 2050 low-carbon strategy.

The draft consists of a Mitigation chapter, an Adaptation chapter and an FAQ (June 2026), which also calls it the ‘Morocco Green Finance Taxonomy’.

What Phase I covers

According to the FAQ published with the draft:

• Two objectives: climate change mitigation and adaptation. The other four (water and marine resources, pollution, circular economy, biodiversity) are built in as DNSH requirements and will be covered more fully in later phases.
• Three sectors for mitigation: energy, transport and manufacturing, which includes chemicals, cement, steel, aluminium, plastics, batteries, textiles, glass and the manufacture of low-carbon technologies.
• Three hazards for adaptation: flooding, heat stress and drought or water stress, with agriculture, forestry and some water infrastructure added.
• Out of scope for mitigation in Phase I: agriculture, buildings, water, waste, forestry and ICT.

Green, Orange, Red

Each eligible activity gets one of three colours. Green: the activity already achieves best-in-class low-carbon performance. Orange (transitional): it does not yet meet the Green thresholds but follows a credible, time-bound decarbonisation pathway, with a default sunset date of 31 December 2035, after which it loses eligibility unless it has moved to Green. Red: the activity is incompatible with climate objectives and cannot carry any green finance label.

The FAQ is clear that a Red classification does not make an activity illegal, trigger a fine or prevent ordinary financing. In its current form the Moroccan taxonomy is a voluntary classification framework; mandatory use would require a separate decision by the regulators, with its own timetable.

EU taxonomy versus Morocco’s taxonomy: what is different for a company?

Both follow the same logic (eligibility, substantial contribution, no significant harm, minimum safeguards), but they differ in status and use. The EU taxonomy underpins a disclosure obligation for large EU companies; the Moroccan draft is first a labelling tool for green finance.

On interoperability, the Moroccan FAQ says that Green criteria and thresholds are aligned as closely as possible with the EU technical screening criteria (the 100 gCO2e/kWh threshold for electricity generation is the same), that Orange criteria are adapted to the national context, and that activities are coded under ISIC Rev. 4. Its DNSH requirements and minimum social safeguards, however, are mostly not aligned with the EU’s. In practice, an activity rated Green in Morocco is not automatically EU-aligned: when the reader is European, the analysis must be redone against EU criteria.

For Moroccan banks, the taxonomy will sit alongside Bank Al-Maghrib’s expectations on climate risk: see our article on the Bank Al-Maghrib climate risk directive and borrowers’ carbon data.

How should you prepare your data for both taxonomies?

Start by mapping your activities, then document emissions, environmental criteria and social safeguards for each one. Most of this data serves both frameworks, as well as your ESG questionnaires and your carbon inventory.

1. Map your activities: break down turnover, CapEx and OpEx by activity, with NACE codes (EU) and ISIC Rev. 4 codes (Morocco). Identify those listed in either taxonomy.
2. Identify who asks for what: a customer reporting an aligned activity, a group consolidating its KPIs, a bank financing a project, an investor in a green bond. The applicable framework follows.
3. Measure emissions: unless the activity sheet says otherwise, the Moroccan thresholds cover Scope 1 and 2 only; a ‘cradle-to-gate’ life cycle assessment is required for some activities (hydrogen, bioenergy, plastics, batteries), using recognised standards such as ISO 14067:2018 (under revision, draft at stage 20.60 on iso.org on 11 November 2026) or the GHG Protocol (also under revision). See our ISO 14064 carbon footprint page.
4. Prove where your electricity comes from: the Moroccan taxonomy sets an order of evidence. First, direct physical supply from a dedicated renewable source behind the meter; then a traceable power purchase agreement backed by cancelled energy attribute certificates; and, by default, the national grid average emission factor.
5. Document DNSH: environmental permits, air emissions and effluent, water management, waste. For manufacturing, the Moroccan FAQ strengthens water-related criteria in line with Water Law 36-15 and requires compliance with national environmental legislation, including Law 13-03 (air emissions) and Law 11-03 (general environmental framework).
6. Demonstrate social safeguards: code of conduct, human rights policy, anti-corruption measures, grievance mechanism. This is the same evidence as for supply chain due diligence.
7. Calculate and keep a trail: for each figure you send, record the source, the method and the date sent, per recipient.

Is your taxonomy data ready?

• Turnover, CapEx and OpEx are broken down by activity, with NACE and ISIC Rev. 4 codes.
  
• Each request is linked to its basis: the customer’s aligned activity, group consolidation, project financing or a green instrument.
  
• No unnecessary work is spent on activities below your customer’s 10% threshold.
  
• Scope 1 and 2 emissions are calculated per site, with dated and sourced factors.
  
• Products concerned have a cradle-to-gate footprint where the activity sheet requires it.
  
• The origin of electricity is evidenced in order: dedicated installation, traceable contract with cancelled certificates, grid average factor.
  
• Site permits and environmental analyses are up to date and filed.
  
• The human rights policy, code of conduct and grievance mechanism are signed and dated.
  
• Questions outside the value-chain cap are identified and handled one by one.
  
• Someone monitors the final version of Morocco’s taxonomy and the revision of the EU criteria.
  

The same data feeds your choice of reporting framework, compared in ESRS, VSME, GRI or ISSB: which ESG framework?. For the investments themselves, see our decarbonisation strategy page.