EU taxonomy

Alliander implements the agreements on the national climate policy. This means that all our activities must contribute to national and international climate goals. We expect the distribution of OpEx, CapEx and revenue growth to increasingly reflect the achievement of these targets.

In order to achieve the objectives of the Paris Agreement by 2050, the European Union drew up the EU Action Plan in 2018 as part of the Green Deal to ensure that the European economy becomes more sustainable. The three main elements of the EU Action Plan are:

• Redirecting capital flows towards a more sustainable economy.

• Making sustainability a permanent aspect of risk management.

• Encouraging transparency and long-term thinking.

The next step was the adoption of the EU taxonomy, a classification system that shows whether cash flows support environmentally sustainable business activities. Under the EU Taxonomy Regulation (EU) 2020/852, companies report three financial indicators regarding environmentally sustainable business activities: turnover, CapEx and OpEx. The EU taxonomy serves six environmental objectives:

• Climate change mitigation.

• Climate change adaptation.

• Sustainable use and protection of water and marine resources.

• Transition to a circular economy.

• Pollution prevention and control.

• Protection and restoration of biodiversity and ecosystems.

Alliander’s operations have to be assessed against the EU taxonomy to establish whether they qualify (are ‘eligible’) as climate-related business activities on the basis of the definition. The assessment of the climate-related business activities involves determining whether they meet the criteria for making a ‘substantial contribution’ to the environmental objectives and also meet the ‘do no significant harm’ criteria in relation to the other five environmental objectives. At a corporate level, it must be determined whether Alliander meets the minimum safeguards with regard to human rights, corruption, tax and fair competition. If the aforementioned conditions are met, these business activities qualify as environmentally sustainable (‘aligned’) under the EU taxonomy.

In this sustainability statement, Alliander reports under the previous EU Taxonomy rules, in accordance with Delegated Regulation (EU) 2021/2178 (the EU Taxonomy Regulation).

Business activities that are eligible under the EU taxonomy

The EU taxonomy (Climate Delegated Act 2021/2139) defines which business activities are climate-related and thus qualify as eligible under the taxonomy. Some of Alliander’s business activities fall under the ‘climate change mitigation’ environmental objective: ‘Transmission and distribution of electricity’ (code 4.9) and ‘District heating/cooling distribution’ (code 4.15). The business activities ‘Transport by motorcycles, passenger cars and light commercial vehicles’ (code 6.5) and ‘Acquisition and ownership of buildings’ (code 7.7) are also reported on; although they do not generate revenue, they do contribute to Alliander’s sustainable objectives as supporting business operations.

Alliander has no business activities that focus on the five other environmental objectives stipulated by the Environmental Delegated Act 2023/2486. The climate-related business activities were therefore assessed on the basis of the ‘climate change mitigation’ objective. They do not overlap with other business activities, so there is no duplication in the reported figures. Transmission and distribution of electricity is an environmentally sustainable business activity under the EU taxonomy.

Alignment assessment

Transmission and distribution of electricity (4.9)

The infrastructure for distributing electricity is part of the European electricity network, so this facilitative business operation meets the criterion relating to substantial contribution.

However, direct connections between the network and third-party production units with emissions exceeding 100 grams CO₂ per kWh do not meet the requirements. Energy meters that are not smart meters are likewise excluded. The financial value of these activities is therefore included in a separate line. Electricity distribution meets the ‘Do No Significant Harm’ (DNSH) criteria for the other environmental objectives; a climate impact assessment has been carried out within the context of climate change adaptation and the criteria relating to circularity, pollution prevention and biodiversity are satisfied.

Heat distribution (4.15)

Heat distribution complies with the substantial contribution criteria (more than 50% of the distributed heat is residual heat) but not with the DNSH criteria. For instance, no climate impact assessment specifically for the district heating networks has been carried out yet. It is also not possible to demonstrate that the DNSH criteria for the marine environmental objective or for pollution prevention have been met.

Transport by motorbikes, passenger cars and light commercial vehicles (6.5)

As regards transport by motorbikes, passenger cars and light commercial vehicles, some of the passenger cars meet the emission requirement of releasing no more than 50 grams CO₂ per kilometre as set in the substantial contribution criteria. The lease companies do not yet have information to determine whether these vehicles also meet the DNSH criteria for the other environmental objectives.

Acquisition and ownership of buildings (7.7)

As regards acquisition and ownership of buildings, we have determined the locations at which investments have been made in new-build or renovation. These projects meet the substantial contribution criteria as regards energy efficiency. No climate impact assessment was performed for this business operation in 2025 to determine which measures have to be taken for climate change adaptation, and no data is available for the other environmental objectives to determine whether they meet the DNSH criteria. Due to the fact that the aforementioned business activities do not meet the DNSH criteria, they cannot be designated as environmentally sustainable.

Business activities that are not eligible under the EU taxonomy
Natural gas distribution and other (supporting) operations are not considered to be climate-related business activities under the EU taxonomy and are therefore not eligible for the EU taxonomy.

Minimum safeguards

We started raising awareness within Alliander and updating the risk analysis with regard to the violation of workers’ and human rights in the value chain. We communicated with fellow network operators and with suppliers in the chain about the introduction of the CSRD and the actions required to gain a better insight into human rights in the value chain and to safeguard them. For components that are made up of many parts, it can be difficult to get a clear picture of the entire value chain. On the other hand, suppliers are often major European businesses that also implement human rights legislation. The introduction of Human Rights Due Diligence in the supply chain is a continuous process aimed at organising human rights monitoring in accordance with international legislation throughout the supply chain and implementing measures to rectify and prevent violations where required. We are expanding due diligence measures to respect workers’ and human rights across our value chain, in line with the expectations of the minimum safeguards from the EU Taxonomy. The added measures include identifying, preventing, mitigating and monitoring actual and potential risks in the value chain, and taking appropriate corrective and remedial action where necessary. For further details, see the ‘Workers in the value chain (S2)’ and ‘Business conduct (G1)’ sections.

For the 2025 reporting year, Alliander does not yet disclose EU Taxonomy alignment, because it cannot yet be proven for all eligible business activities that all requirements regarding the minimum safeguards are being met.

Financial information

The turnover under the EU taxonomy (Disclosure Delegated Act 2021/2178) is consistent with IFRS reporting standards and is therefore equal to the net revenue included in the financial statements under note 21. The turnover is allocated to Alliander’s various business operations on the basis of sales records. The table shows how each operation is classified under the EU taxonomy. The CapEx relates to investments in property, plant and equipment (note 3), investments in intangible assets (note 4) and additions to right-of-use assets (note 3). Investments associated with assets held for sale are not part of this CapEx. The portion of the total investments that concerns climate-related business activities was determined by identifying the economic activity to which each asset group is related and assessing whether this activity is mentioned in the EU taxonomy. The OpEx under the EU taxonomy is defined as the non-capitalised direct costs for preserving the assets. Based on this definition, Alliander has only classified maintenance and outage costs as operating expenses under the EU taxonomy. We have determined which part of these maintenance and outage costs is associated with climate-related business activities based on the underlying work order and project records.

Activities in relation to nuclear energy and non-renewable gas