Suppose a company has a project under an eligible activity, like Data processing, hosting and related activities. Employees may travel to sites or suppliers to support the project, generating travel expenses. They may also spend time directly working on the implementation of the project.
Can these travel costs and employee hours be included in the OPEX numerator as part of the project’s expenditures?
From what I understand in the Delegated Regulation (EU) 2021/2178, these costs can be included as long as they are directly linked to the eligible project and are not capitalised. The transport itself doesn’t need to be green or eligible, what matters is the connection to the aligned or eligible activity. Is this right?
This means that travel costs and direct employee expenses (e.g. working hours) can be reported as part of the project’s OPEX, rather than under separate activities like Transport by motorbikes, passenger cars and light commercial vehicles.
Of course, care must be taken to avoid double counting.
Has anyone dealt with this before or received specific guidance on it?
1 Answer
Anonymous User
Key Principle: Direct Link to Eligible Activity
Both employee travel expenses and employee hours can be reported in the numerator of Taxonomy-eligible OpEx, as long as:
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They are not capitalised (i.e. they remain as operating expenditures),
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They are directly linked to the implementation of a Taxonomy-eligible activity, and
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They are properly documented (via time tracking, cost allocation, travel records, etc.).
As you already said: Avoid double counting!
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Double Counting: Avoid including the same expenditure in multiple categories (e.g. don’t count it in both the aligned CapEx and OpEx numerator).
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Allocation and Proportionality: If an employee only works 40% of their time on the eligible activity, only 40% of their salary and related travel can be included.
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Consistency: You should apply the same logic across projects and reporting periods.
