Investing in the Age of AI
EU Taxonomy, Regulatory ComplianceArticles

EU Taxonomy Reporting: Incorrect Use of NACE Codes Can Lead to Greenwashing

Published: October 28, 2022
Modified: April 23, 2025
Key Takeaways

The European Commission warns once again about the risks of solely relying on NACE codes for EU Taxonomy reporting

As organizations classify EU Taxonomy activities there is a natural tendency to overestimate eligibility. If you don’t examine each activity thoroughly, you risk  greenwashing the technical criteria associated with the activity.

The European Commission initially mentions mapping NACE codes with EU Taxonomy activities, however, they recently published a FAQs document to provide additional guidance on how to report on eligible economic activities and assets under the EU Taxonomy Regulation. The document highlights how users can use NACE code “to navigate through the Taxonomy” but warns -once again- that the scope of the activities outlined in the Climate Delegated Act should prevail.

“The NACE codes should only be understood as indicative and should not prevail over the specific definition of the activity provided in its description” – European Commission

Some background on the NACE code

The NACE code is the Statistical Classification of Economic Activities in the European Community, the industry standard used in the EU. Each activity within the EU Taxonomy will tell you the NACE code that the activity can be associated with. One thing to keep in mind is that the EU Taxonomy and the NACE code were created based on different motivations and drivers so although it is helpful to relate associated activities and even use them as a proxy when appropriate we must remember that they are not a perfect match. 

Clarity AI increases accuracy with best-in-class treatment of NACE codes

Clarity AI goes beyond the surface to not just assume direct match between the business activity and NACE code. In fact, we use the exact description in the technical annex. Looked at in detail, there are very specific definitions associated with each activity.

Let’s take “Data processing, hosting and related activities” as an example. According to the technical annex, this category could be associated with “NACE code J63.11”. Viewing the activity on its own you may assume it’s an eligible activity but if you dig into the details of the technical annex it focuses on one specific area and not the total activities listed under the NACE code.

Learn more about incorrect uses of the NACE codes through relevant case studies.

Access Case Studies

Research and Insights

Latest news and articles

Regulatory Compliance

Sustainable Finance Regulation in 2026: Fragmentation, Data Gaps, and the New Reality for Investors

Are we entering a new era of pragmatic complexity, or simply losing the thread of the sustainability agenda? With this question, Lorenzo Saa, Chief Sustainability Officer at Clarity AI, opened a recent conversation with Patricia Pina, Clarity AI’s Chief Research Officer, and Cornelius Müller, Policy Officer at the Sustainable Banking Coalition. The group discussed over…

Climate

The Climate Risk Toolkit: Scenarios, Models, and Getting it Right

Climate risk disclosure has shifted from a differentiator to the baseline, and the expectations keep moving. Institutional investors must now disclose and manage climate-related risks across multiple warming scenarios. The challenge is how: Join us to explore how financial institutions are operationalising climate risk through scenario analysis, forward-looking metrics, and AI-driven workflows. Through real case…

AI

What AI Adoption Really Looks Like in Finance: A Conversation at the NYSE

Clarity AI's Lillian Freiberg joins FintechTV at the NYSE to discuss AI adoption, mandate execution, and smarter investment workflows.