Disclosures under the EU Taxonomy Regulation (EU) 2020/852

Pursuant to Article 8 of Regulation (EU) 2020/852 of 18 June 2020 on the Establishment of a Framework to Facilitate Sustainable Investment, TUI AG reports in accordance with the Taxonomy Regulation. Initially, it must be stated which portion of revenues, capital expenditure and operating expenditure of TUI are associated with economic activities described in EU Regulations and Delegated Acts and are thus considered taxonomy-eligible. Additionally, the proportion of these KPIs that can be classified as environmentally sustainable or taxonomy-aligned according to Articles 3 and 9 of the Taxonomy Regulation must be reported.

Environmental sustainability is assessed using technical screening criteria for the following 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.

An economic activity qualifies as environmentally sustainable or taxonomy-aligned if it demonstrably makes a substantial contribution to one of the six environmental objectives and does not significantly harm any of the other environmental objectives. Furthermore, the economic activity has to ensure minimum standards on human rights, including social and labour standards, standards relating to anti-corruption, fair competition and taxation.

For financial year 2023, only economic activities for the environmental objectives of climate change mitigation and climate change adaption were defined by corresponding regulations. These economic activities, if relevant to TUI, are examined for taxonomy eligibility and alignment as in previous years and reported accordingly. As of 1 January 2024, additional economic activities for the remaining environmental objectives became reportable. Accordingly in financial year 2024 additional TUI activities fell under the EU Taxonomy. These include in particular activity 6.19 “Passenger and freight air transport”, which is assigned to the environmental objective “Climate change mitigation”, and activity 2.1 “Hotels, holiday, camping grounds and similar accommodation”, which is assigned to the environmental objective “Protection and restoration of biodiversity and ecosystems”. This marked the first time that TUI’s core activities were covered. For these activities newly identified last year, the assessment of taxonomy alignment is being conducted for the first time in this reporting year. Compared to the previous year, no new activities became reportable in financial year 2025.

Some of the terms and definitions used in the EU Taxonomy regulations are still unclear with regard to their meaning and interpretation. The EU regularly publishes statements (FAQs) for clarification. Due to the unclarities and the amendments to regulations, TUI incurs the risk of facing a different future interpretation of these indicators and having to change its reporting accordingly.

The amendments to the EU Taxonomy regulations proposed by the European Commission on July 4, 2025, as part of the Omnibus procedure, have not yet entered into force. These amendments are expected to apply from January 1, 2026. Consequently, TUI AG’s reporting for the 2025 financial year does not reflect these changes.

Determination of economic activities qualifying as taxonomy-eligible

As a first step, TUI analysed its economic activities to determine whether they correspond to the activities defined in the EU Taxonomy. In doing so, TUI took into account both of economic activities generating external revenue and activities serving its own needs.

The second step was to determine KPI for these economic activities. Where a KPI relates to several economic activities at once, it was broken down, usually based on the direct costs incurred for the activity in question. The reported numbers only include the revenue, capital expenditure and operating expenditure of companies fully included in the consolidated financial statements.

Checking technical screening criteria

Compliance with the relevant technical screening criteria is determined by consulting the respective Group companies or by means of a screening based on higher-level processes and within the framework of national or EU regulations. Where it was not possible to check compliance with technical screening criteria for lack of data or evidence and the economic activity concerned is not material for TUI, no screening was carried out and the economic activity was classified as non-aligned with the Taxonomy in accordance with Commission Notice C/2023/305 dated 20 October 2023, no. 13. The results are described in the following sections on revenue, capital expenditure and operating expenditure.

Checking minimum protection criteria

TUI ensures compliance with the minimum protection criteria through Group-wide policies, training programmes, codes of conduct and risk management systems, which also cover our suppliers and the impact of the services we provide. On compliance with human rights, we refer to the Non-Financial Group Declaration in particular the explanation on ESRS S1, S2 and S4, and with respect to anti-corruption and fair competition, to ESRS G1. In addition, we refer to the Corporate governance report. TUI has also implemented a tax strategy designed to ensure that we are taxed in a manner concomitant with our business, to prevent aggressive or artificial tax planning, to facilitate cooperation with local tax authorities and to manage and review tax risks centrally. In this context, please refer to the publication of our tax strategy at Reports & Documents | TUI Group - One of the world's leading tourism groups. At the reporting date, no relevant litigation was pending in this context.

Revenue

Total revenue is the revenue determined in accordance with international accounting standards and carried as revenue in the Notes. Only revenues of consolidated subsidiaries will be reported as taxonomy-eligible or taxonomy-aligned.

In the TUI Musement segment, customer transport in the destination, e.g. for excursions or transfers between the airport and the hotel, was allocated to economic activity 6.3 “Urban and suburban transport, road passenger transport”. The revenue numbers were taken from our internal reporting system. Where this revenue also related to other economic activities, e.g. in the case of excursions involving not only transport but also guided tours, it was allocated on the basis of direct costs. Revenue from coach transport services provided by third parties is only recognised if this revenue meets the definitions of international accounting standards and if TUI controls the underlying processes.

The revenue generated in the Cruises segment is allocated to economic activity 6.11 “Sea and coastal passenger water transport”. Revenue in the Northern Region segment includes revenue from economic activity 6.7 “Inland passenger water transport”. The revenue is regularly generated from sales of package tours consisting, for example, of a flight, transport to the destination and overnight accommodation on a ship. For the purposes of the EU Taxonomy, this revenue is broken down in line with the direct costs incurred so as to determine the revenue attributable to passenger transport by ship.

The revenue earned from the economic activities 6.19 “Passenger and freight air transport” and 2.1 “Hotels, holiday, camping grounds and similar accommodation” are generated in the Northern Region, Central Region, Western Region and Hotels & Resorts segments. These activities encompass flight operations and the accommodation services offered by TUI and are therefore core activities. Where revenue is generated as part of a package tour, the taxonomy-eligible revenue is derived from intra-Group costs. In financial year 2025, the internal reports forming the basis for calculating revenues for economic activity 2.1 ‘Hotels, holiday, camping grounds and similar accommodation’ were comprehensively redesigned. To ensure year-on-year comparability, the revenues for financial year 2024 were adjusted accordingly. Furthermore, these revenues have been adjusted to eliminate duplicate entries that were included in the prior year. Revenue generated on the basis of flight or hotel capacity provided by third parties is only recognised if it meets the definitions of international accounting standards and if TUI controls the underlying processes.

The proportion of total revenues accounted for by taxonomy-eligible revenues decreased from 36,4% to 35,4%. The decrease is caused by a higher share of dynamic packaging solutions in financial year 2025 in comparison to prior year. TUI does not pre-commit for flight or accommodation capacity in relation to dynamic packaging, accordingly the share of revenues based on controlled processes declined. TUI did not report any taxonomy-aligned revenues.

Revenues from activity 6.19 “Passenger and Freight Air Transport” do not fully meet the criteria for taxonomy-alignment, partly because the EU Taxonomy Regulation considers the use of certain chemicals as impairing other environmental objectives. However, these chemicals are employed in flight operations for safety reasons, in compliance with other EU regulations. The amendments to the EU Taxonomy proposed under the so-called Omnibus procedure would modify this requirement. Once the legal act becomes applicable, TUI expects an increase in taxonomy-aligned revenues.

Capital expenditure

Capital expenditure summarises the additions to the relevant assets mentioned in the Notes in the sections “Goodwill”, “Other intangible assets”, “Property, plant and equipment” and “Right-of-use assets”. In financial year 2024, additions from mergers were carried under Other intangible assets (€1.1m).

The total capital expenditure of €1,055.7m breaks down as follows for financial year 2024:

Other intangible assets €154.0m

Property, plant and equipment €751.7m

Right-of-use assets €150.0m

As a rule, capital expenditure is allocated to individual economic activities on the basis of our internal project controlling and account assignments in Group reporting. Overall, taxonomy-eligible capital expenditure accounts for 79.8% of total capital expenditure (previous year 71.3%). The year-on-year increase is mainly due to the increased capital expenditure for aircrafts and hotels. In financial year 2024 no taxonomy-aligned capital expenditure was reported.

Operating expenditure

TUI’s operating expenditure includes non-capitalised direct expenditure for building refurbishment, short-term leases, maintenance and repair as well as any other direct expenditure incurred in connection with the day-to-day maintenance of property, plant and equipment, intangible assets and right-of-use assets. Where necessary, operating expenditure is allocated to an economic activity on a cost basis. The allocation to economic activities follows the allocation of capital expenditure. The review of the taxonomy eligibility and alignment of operating expenditure follows a review of the respective property, plant and equipment, other intangible assets or right-of-use assets to which they can be allocated. Accordingly, no taxonomy-aligned operating expenditures were identified. Taxonomy-eligible operating expenditure thus accounts for 92,4% of total operating expenditure (previous year 91.5%).