The finance controller at a listed industrial group in Milan has a SAP export on one screen, a 340-row CapEx register on another, and the Climate Delegated Act PDF open to page 112 — the technical screening criteria for "Manufacture of iron and steel." Her audit partner has asked, politely, whether the €18M boiler retrofit booked in Q3 is an enabling activity, a transitional activity, or neither. She does not know. Her colleague in treasury does not know. The consultant who quoted €62,000 to find out is on holiday until Tuesday.
She has six weeks until the annual report signs off. The Turnover, CapEx, and OpEx KPIs under Article 8 of the Delegated Act have to land in the non-financial statement with numerator, denominator, and a DNSH narrative for every aligned activity. The denominator is the easy part.
There are three ways to deal with this. We watched all of them play out.
Option A: Hire a Consultant (The Old Habit)
This is what most listed companies do for their first — and second, and often third — Taxonomy cycle. You call your statutory auditor's advisory arm, or one of the other Big Four, or a boutique sustainable-finance shop that splintered off from one of them two years ago. They quote somewhere between €30,000 and €80,000 for a mid-cap, more if your NACE codes span several annexes, more again if the auditor flags the work as in-scope for limited assurance.
The rhythm is predictable.
Week 1 — Scoping. Kick-off call with four people from the consultant and two from you. They request your chart of accounts at the 6-digit level, your CapEx register, your operating expense ledger for R&D and building maintenance, your revenue segmentation by product line, and a sustainability policy document that nobody on your team remembers writing. Half of this is already in SAP. Getting it out takes IT three days.
Week 2 — Eligibility mapping. The junior associate maps your NACE codes to the Delegated Act activities. She gets most of them right. She flags twelve revenue lines as "ambiguous" and wants a workshop. Your operations director has 45 minutes for the workshop. You resolve five.
Week 3 — Alignment and DNSH. This is where the budget goes. For every activity that passes the substantial contribution test, the consultant needs to walk through six DNSH criteria — climate adaptation, water, circular economy, pollution, biodiversity, and whichever was the substantial contribution objective. For each one, they ask for evidence. Climate risk assessment? "We don't have one documented." Water use policy for the Ravenna plant? "We have a permit but not a policy." And so on, for every aligned activity, for every objective.
Week 4 — Draft and revision. You get a 70-page report. The Turnover KPI says 34% aligned. The CapEx KPI says 61% aligned, driven almost entirely by the boiler retrofit that they've classified as a transitional activity under 3.9. The OpEx KPI says 12% aligned. Your CFO questions the boiler classification. The consultant escalates to a partner, who bills two hours at €480 to confirm the junior got it right.
Total time: 3 to 4 weeks. Total cost: €30,000 to €80,000.
What you get
- A defensible Article 8 disclosure, probably correct
- A partner signature on a cover memo
- A DNSH evidence binder your auditor will actually accept
- Zero institutional learning — next year, you repeat the engagement at a 10% loyalty discount
What you don't get
- Anybody on your team who could do this without them next year
- A traceable link between a disclosed KPI and the line in the CapEx register it came from
- Speed
Option B: A Taxonomy Platform (The Software Layer)
After the second invoice, finance controllers start searching "EU Taxonomy software" and discover a real market. Greenomy is the specialist most banks recommend. Position Green comes in from the ESG-suite side. Workiva has a Taxonomy module bolted onto its reporting engine, which makes sense if you already use Workiva for statutory filings. Novisto and Sweep round out the short list for larger filers.
These tools are a genuine step up. They're also not magic.
Week 1 — Setup. You sign the order form (€10,000 to €30,000 per year, depending on scope and seat count), onboard your team, and import your chart of accounts and CapEx register via CSV or a prebuilt SAP connector. The platform loads the Delegated Act activity library, the technical screening criteria, and a DNSH questionnaire template.
Week 2 — Mapping and questionnaires. Your team maps revenue lines to Taxonomy activities through a guided UI. Better than Excel. The platform flags which activities need which DNSH checks, routes the climate risk question to your EHS manager, routes the minimum safeguards question to your HR head, and routes the circular economy question to your head of operations. They get emails. Some of them reply.
Total time: 1 to 2 weeks. Total cost: €10,000 to €30,000/year subscription.
What you get
- Structured, repeatable workflow — next year is genuinely faster
- A single source of truth for the numerator/denominator calculation
- XBRL tagging for the Art 8 disclosure
- Collaboration features that route DNSH questions to the right internal owner
What you don't get
- Interpretation. The platform shows you the DNSH criteria. It doesn't tell you whether your Ravenna plant's wastewater permit satisfies criterion 2 for water use.
- Relief from the drafting burden. Someone still writes the narrative.
- Help when your chart of accounts doesn't align cleanly to NACE codes. You'll still do that mapping in a meeting.
- A home for your CBAM, CSRD, and CDP work — the Taxonomy module is one of several you'd pay for, and the data doesn't always flow between them.
Option C: Formist (The Three-Hour Version)
Formist, built by WeCarbon, is an AI-powered compliance platform that works like a colleague who has read the Delegated Acts, memorized the NACE code tables, and has the patience to walk through every DNSH criterion with you. You upload documents, it asks questions, it drafts the disclosure. It handles EU Taxonomy, CBAM, CSRD/ESRS, GHG Protocol, CDP, ISSB, and 15+ other frameworks under one subscription, which matters because the same CapEx line you just classified for Taxonomy shows up in your CSRD E1 transition plan and your CDP climate questionnaire — typing it in three times is not a job.
Here is the finance controller in Milan's actual afternoon.
Hour 1 — Eligibility. She uploads her SAP chart-of-accounts export, her CapEx register, her OpEx ledger for R&D and building maintenance, and her revenue segmentation by product line. The Formist AI agent reads all of it, in whatever language it's in, and proposes a mapping: 14 revenue activities mapped to four Delegated Act categories, 23 CapEx line items mapped to seven, the boiler retrofit flagged as a candidate transitional activity under 3.9 "Manufacture of iron and steel" with a footnoted explanation of why. She accepts 31, rejects 2, and asks it to re-explain 3. The re-explanations cite paragraph numbers.
Hour 2 — Alignment and DNSH. This is the part that used to take a week. For each eligible activity, Formist walks through the substantial contribution test, then each of the six DNSH criteria, and asks only for what it can't already infer from your documents. "For activity 3.9, the climate adaptation DNSH requires a physical climate risk assessment covering the Ravenna site — do you have one? If yes, upload it. If no, I'll flag this as non-aligned and tell you exactly what would make it aligned." She uploads the ERM climate risk assessment from 2024. Formist extracts the site-level findings, cites the relevant pages, and confirms the criterion is met. It does the same for water (permit + extraction data), pollution (IPPC BAT conclusions), biodiversity (no Natura 2000 overlap — checked against coordinates she uploaded), and circular economy (waste management plan). For minimum safeguards, it cross-references her human rights policy, her OECD MNE alignment statement, and her grievance mechanism against the UN Guiding Principles checklist.
Hour 3 — KPIs, narrative, and review. Formist calculates the three KPIs from the mapped line items: Turnover 34.2% aligned, CapEx 61.8% aligned, OpEx 12.4% aligned. Every number is linked back to the specific line in the source document it came from — click the CapEx figure and you see the 47 register rows that feed it. It drafts the Art 8 narrative, fills the mandatory templates from Annex V of the Disclosures Delegated Act, and produces the XBRL tags. She reviews in a structured card view, corrects the transitional-activity justification to reference the group's net-zero plan (Formist hadn't seen that document), and exports.
Total time: about 3 hours of her time. Total cost: a subscription that costs less than a single day of a Big Four senior associate.
What you get
- A Turnover/CapEx/OpEx calculation that traces to your ledger, line by line
- DNSH evidence logged per-criterion with source citations your auditor can follow
- Draft Art 8 disclosure narrative, templated, editable, in your voice once you edit it
- The same platform for your CSRD E1, CBAM filings, and CDP climate questionnaire — the Taxonomy data flows into all of them
- Institutional knowledge that stays with you, not with a firm
What you don't get
- A partner's signature on a cover memo. If your credit facility requires "PwC" on the front page, you still need a consultant for that last mile.
- Someone to blame if the boiler classification turns out wrong. Formist shows its reasoning, but the accountability is yours.
The Full Comparison
| Dimension | Big Four Consultant | Taxonomy Platform | Formist AI Agent |
|---|---|---|---|
| Filing time | 3 to 4 weeks | 1 to 2 weeks | ~3 hours |
| Expertise required | None — you outsource the Delegated Acts entirely | Medium — you need to understand eligibility, alignment, and DNSH well enough to answer the questionnaires | Low — Formist walks you through the Delegated Acts in plain language and asks for documents, not jargon |
| Labor cost | €30K–€80K per cycle, billed fresh each year | €10K–€30K/year subscription + 40–80 internal person-hours | Subscription fee + ~3 hours of controller time for the KPIs and DNSH |
| Accuracy | Depends on the junior associate's thoroughness; partner review is a few hours at most | Standardized logic; platform enforces criteria consistency but doesn't interpret edge cases | Formist cross-checks every alignment claim against source documents and the Delegated Act text; flags ambiguous cases |
| Data traceability | Evidence binder in SharePoint, loosely linked to the disclosed number | All data lives in the platform; clickthrough to the input row | Every KPI number links to the ledger line, every DNSH conclusion links to the source document paragraph |
| Risk management | Partner's letter provides comfort; audit trail depends on file discipline | Platform logs who answered which DNSH question and when | Formist produces an audit-ready reasoning trail per criterion, with citations the assurance team can verify without calling anyone |
Where the Time Actually Goes: DNSH
Here is the thing the scoping calls don't say. The Turnover/CapEx/OpEx split is largely a chart-of-accounts exercise. If your ledger is clean, a competent analyst can do the eligibility mapping in two days. Maybe three.
DNSH is where weeks disappear. Six criteria per activity, times however many activities you have aligned, times the evidence collection and narrative writing for each. A consultant charges you by the hour for DNSH because DNSH is pure hours. A platform routes DNSH questions to your EHS manager and your HR head, then waits for them to reply, which they do in their own time. Formist reads the documents they already wrote and answers most of the questions before asking any of them.
The controller in Milan, asked afterward what surprised her, said this: the consultant's €62,000 quote was for 3.5 weeks of a senior and an associate mostly writing DNSH narratives from her inputs. Formist read her 94-page ERM climate risk assessment, extracted the site-level findings for Ravenna, and mapped them to the DNSH climate adaptation criterion in under four minutes. She had assumed the slow part of Taxonomy was the regulation. It isn't. The slow part is reading a binder of documents and writing a paragraph that cites the right page.
The Clock on Art 8 Disclosures Is Already Running
For listed non-financial companies in scope of Article 8 of the Taxonomy Regulation, full Turnover, CapEx, and OpEx alignment disclosures against the first two environmental objectives have been mandatory since FY2023. Since 1 January 2024, the remaining four — water, circular economy, pollution, biodiversity — are in scope too. Financial undertakings phased in their Green Asset Ratio and related KPIs over 2024 and 2025.
What's coming in the near term tightens the screws further. The Omnibus I proposal published by the Commission in February 2025 reshuffled CSRD scope but did not relieve Article 8 Taxonomy disclosure obligations for companies that remain in scope — it simplified the reporting template for some filers, not the underlying classification work. Limited assurance on Taxonomy KPIs is now the working expectation of most statutory auditors for FY2025 reports landing in 2026, even where the directive doesn't mandate it yet. And the Platform on Sustainable Finance's ongoing recommendations point toward tightening DNSH criteria, not loosening them.
The net effect: your auditor will ask harder questions this year than last year. "Show me the DNSH evidence for activity 3.9" is now followed by "and show me the methodology you used to assess physical climate risk against the Delegated Act's Appendix A classifications." If your answer is "the consultant has it," that's increasingly not an acceptable answer.
Where to Start If You're Filing This Year
Don't replatform in Q4. Here is what we'd actually suggest.
- Run one KPI through Formist before your next audit committee. Pick CapEx — it's the KPI where alignment percentages move most, and where your controller already has the register. Upload it, watch the agent do the mapping, and compare the output to what your consultant produced last year. Most of the time the numbers match within a rounding error, and the audit trail is cleaner.
- Keep your consultant on a narrower scope. Novel activities, genuinely ambiguous classifications, disputes with the statutory auditor, and the cover memo — all worth paying for. Writing 60 DNSH paragraphs is not.
- Stop paying for year-one work in year three. If you're on your third cycle and the quote looks like your first cycle, ask why. The materiality of your operations didn't change. The scope didn't change. The only thing that changed is who has the institutional memory — and right now, it's the firm, not you.
The EU Taxonomy will be a recurring, annual, auditable line in your non-financial statement for the rest of your finance career. The question isn't whether you automate the mechanical parts. It's how many more years you pay someone else to do it for you.
Formist is built by WeCarbon, a climate-tech company with offices in Shanghai, Paris, and Dubai. It supports EU Taxonomy, CSRD/ESRS, CBAM, GHG Protocol, CDP, ISSB, SBTi, and 15+ other sustainability frameworks.