The European Commission’s Delegated Act simplifying the EU Taxonomy was published in the Official Journal on 8 January 2026 and entered into force on 28 January 2026 (for the fuller picture of what the Omnibus package changed across sustainability reporting more broadly, see our breakdown of the EU Omnibus and physical climate risk).
What the Omnibus Simplification Actually Changed
For real estate and other reporting entities, three changes matter most:
- Fewer data points. Reporting templates were cut by roughly 64% for non-financial undertakings and 89% for financial undertakings.
- A materiality threshold. Companies can now exclude activities from alignment assessment if they cumulatively represent less than 10% of total turnover, capex or opex.
- A narrower reporting population. Because Taxonomy Article 8 scope is tied to the CSRD, the same Omnibus narrowing that reduced CSRD’s population, to companies above 1,000 employees and EUR 450 million net turnover, also reduces who has a mandatory obligation to report Taxonomy alignment.
What Has Not Changed
The technical screening criteria for the climate change adaptation objective are unchanged in substance. To claim Taxonomy alignment for an economic activity, real estate stakeholders still need to:
- Screen the activity to identify the physical climate hazards that could affect it over its expected lifetime.
- Where risks are identified, carry out a climate risk and vulnerability assessment using forward-looking climate scenarios appropriate to the asset’s lifespan.
- Identify and implement adaptation measures that address the risks, without creating maladaptation elsewhere.
- Satisfy the Do No Significant Harm (DNSH) principle across the Taxonomy’s other environmental objectives.
None of this has been removed. It has simply been decoupled, for many companies, from a mandatory reporting obligation.
What This Means in Practice for Real Estate
- If you’re still in scope: fewer datapoints to report, but the same underlying risk-assessment work behind the numbers.
- If you’ve fallen out of mandatory scope: Taxonomy alignment remains a voluntary signal that matters for green financing, tenant demand and asset value, and demonstrating it still requires the same climate risk and vulnerability assessment as before.
- The 10% materiality threshold cuts both ways. It’s a genuine compliance relief, but applying it mechanically risks excluding exactly the assets with the most acute physical exposure, the ones a lender or insurer is most likely to ask about anyway.
The Omnibus has changed who is required to report Taxonomy alignment. It has not changed which buildings are exposed to flooding, heat stress or storm damage, or what a credible adaptation assessment looks like.
How exposed is your portfolio? Visit our website or connect with us on LinkedIn to learn more about our climate risk and adaptation assessments.