Climate material
Report E1 for the material sub-topics, with ESRS 2 always.
ESRS E1 ¶2; ESRS 1 ¶30.EU reporting · the climate standard
ESRS E1: the eleven climate disclosures, and when they apply
ESRS E1 Climate Change is the EU’s climate standard under the CSRD, and its revised form has eleven disclosure requirements, from the transition plan to anticipated financial effects.
It applies to financial years beginning on or after 1 January 2027, and only where climate relates to material impacts, risks or opportunities.
For a UK group the useful question is what E1 asks that UK SRS S2 does not, and the other way round.
What E1 covers
ESRS E1 in one paragraph, and its three sub-topics
ESRS E1 sets out what an undertaking discloses about climate once its assessment finds climate material.
¶6 names three sub-topics: “climate change mitigation, climate change adaptation and energy.”
Read the scope paragraphs
¶10(a) says E1 “covers, but is not limited to, the seven GHGs: CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3.”
Ozone-depleting substances and other air emissions sit in ESRS E2, and the effects of the transition on people sit in the social standards S1 to S4.
The text is Annex I of Delegated Regulation (EU) 2026/1563, published in the Official Journal on 21 September 2026; the twelve standards as a set are on the ESRS guide.
Three sub-topicsExplore
Module 01 / 04
Mitigation
Efforts to limit warming to 1.5 °C in line with the Paris Agreement and the European Climate Law (¶7).
Module 02 / 04
Adaptation
Adjustment to actual and expected consequences of climate change, including physical risks (¶8).
Is E1 compulsory?
ESRS E1 is reported only where climate is material
¶2 says the statement provides E1 information “if this topic relates to material impacts, risks and opportunities.”
If only some sub-topics are material, ¶1 applies ESRS 1 ¶30: report only the material information for that sub-topic.
Read how the climate conclusion is disclosed
The assessment itself is the double materiality assessment under revised ESRS 1, Chapter 3.
Climate is treated differently on the way out: if it is judged not material, ESRS 2 IRO-2 asks for the basis of that conclusion.
For most large undertakings climate will be material, but that is the outcome of the assessment, not a rule of E1.
The datapoints in E1 are all subject to materiality; EFRAG’s draft list of 28 August 2026 says the revised ESRS “have no mandatory datapoints that are to be reported irrespective of materiality assessment”, as set out on ESRS datapoints.
The materiality assessment
Climate not material
E1 is not reported; ESRS 2 IRO-2 asks for the basis of that conclusion.
ESRS 2 IRO-2.The disclosure requirements
All eleven ESRS E1 disclosures, one by one
The titles below are the published ones.
Paragraph numbers are those of the revised E1 and do not carry over from the 2023 text.
| DR | Title | What it asks |
|---|---|---|
| E1-1 | Transition plan for climate change mitigation | ¶12: key features, coal/oil/gas CapEx, assumptions, locked-in emissions, progress; ¶13 if none, say so and when one is expected. |
| E1-2 | Identification of climate-related risks and scenario analysis | ¶¶15–16 risk classification and methodology; ¶17 scenario disclosures only if scenario analysis is used. |
| E1-3 | Resilience in relation to climate change | ¶19 results, uncertainties and capacity to adapt; AR 9 not required annually. |
| E1-4 | Policies related to climate change mitigation and adaptation | ¶20, through ESRS 2 GDR-P. |
| E1-5 | Actions and resources in relation to climate change mitigation and adaptation | ¶¶21–22, through GDR-A, by decarbonisation lever. |
| E1-6 | Targets related to climate change | ¶¶23–24 absolute targets for Scopes 1–3; science-based statement; AR 12 gross targets. |
| E1-7 | Energy consumption and mix | ¶¶26–28 MWh by fossil, nuclear and renewable sources. |
| E1-8 | Gross scope 1, 2, 3 GHG emissions | ¶30 Scope 1 with EU ETS share, Scope 2 location- and market-based, significant Scope 3; ¶31 biogenic CO2. |
| E1-9 | GHG removals and GHG mitigation projects financed through carbon credits | ¶¶33–35 removals, credits cancelled and purchased, neutrality claims. |
| E1-10 | Internal carbon pricing | ¶37 how carbon pricing is used and the average price per tonne. |
| E1-11 | Anticipated financial effects from material physical and transition risks and material climate-related opportunities | ¶¶39–42 assets and revenue at risk, methodology, opportunities; phased in. |
E1-1
The transition plan: describe it, or say you have none
E1-1 does not oblige an undertaking to have a transition plan; it obliges it to describe the one it has, or to say it has none.
¶13: if there is no plan with the key features, the undertaking “shall disclose this fact and indicate whether and, if so, when it expects to adopt one.”
Read ¶12 in full
¶12(a) covers the plan’s key features: GHG emission reduction targets, decarbonisation levers, key actions, investments and funding, approval by the administrative, management and supervisory bodies, and alignment with strategy.
It also asks how the strategy and business model are or will be compatible with limiting warming to 1.5 °C and with climate neutrality by 2050.
¶12(b) to (e) add fossil-fuel CapEx, key assumptions and dependencies, locked-in emissions and progress.
AR 1 says the plan can stand alone or sit within a broader plan covering adaptation, and AR 2 asks for a statement on whether targets are science-based and compatible with 1.5 °C.
The wider UK picture of transition plans is on climate transition plans.
E1-1 key featuresExplore
Module 01 / 04
Key features
Targets, decarbonisation levers, key actions, investment and funding, board approval, alignment with strategy (¶12(a)).
Module 03 / 04
Locked-in emissions
How locked-in emissions from key assets and products may jeopardise the plan (¶12(d)).
E1-2 and E1-3
Scenario analysis only if used, resilience not every year
E1-2 asks how climate-related risks and opportunities were identified for financial materiality, and ¶17 applies only “if climate-related scenario analysis is used”.
E1-3 asks about resilience, and AR 9 says the analysis need not be performed “on an annual basis”.
Read the scenario and resilience provisions
Where scenarios are used, ¶17 asks whether at least one high-emission scenario was used for physical risk and at least one 1.5 °C scenario with no or limited overshoot for transition risk, plus scope, assumptions and timing.
AR 6 says the undertaking “may use climate-related scenario analysis”, for example where it uses such analysis to comply with other requirements or another reporting framework.
AR 9 adds that if the undertaking has updated its assessment of climate-related impacts, risks and opportunities under E1-2, it shall update its resilience analysis.
This is the clearest difference from UK SRS S2, which requires scenario analysis and an annual resilience assessment.
Risk and resilienceExplore
Module 02 / 04
Methodology
How exposure and sensitivity to hazards and transition events were assessed (¶16).
Module 03 / 04
Scenarios, if used
A high-emission scenario for physical risk and a 1.5 °C scenario for transition risk (¶17).
Module 04 / 04
Resilience
Not required annually; updated when the risk assessment is updated (AR 9).
E1-6, E1-7 and E1-8
Targets, energy and emissions: the ESRS E1 metrics
E1-8 asks for gross Scope 1, 2 and 3 emissions in tonnes of CO2-equivalent, with Scope 2 “location-based and market-based”.
E1-6 asks for the targets set, and AR 12 makes them gross: no removals, carbon credits or avoided emissions count towards them.
Read the boundary, Scope 3 and energy rules
AR 19 sets the boundary at financial control as per the GHG Protocol Corporate Standard, and says the undertaking “may use the equity share or operational control approach” instead.
AR 24 asks for a screen of the 15 Scope 3 categories, or the EN ISO 14064-1 categories, and identifies significant categories by magnitude and criteria such as financial spend, influence, transition risks and opportunities or stakeholder views.
¶31 asks for direct biogenic CO2 separately from Scope 1, and ¶30(c) splits Scope 1 and 2 between the consolidated accounting group and other emissions.
E1-7 asks for total energy consumption in MWh by fossil, nuclear and renewable sources, with a fossil breakdown for undertakings in high climate impact sectors.
E1-6 ¶24(c) asks for a statement on whether targets are science-based and compatible with 1.5 °C, and which framework was used.
The underlying accounting is on Scope 3 emissions and Scope 2 emissions.
The E1 metricsExplore
Module 03 / 04
Scope 3
Each significant category, total and per category (¶30(a)(iii)).
Module 04 / 04
Targets
Absolute targets for Scopes 1–3; gross, no credits or removals (¶24, AR 12).
E1-9 and E1-10
Carbon credits and carbon prices are disclosed, not netted
E1-9 keeps carbon credits apart from the emissions figures: they are reported as credits, never deducted from targets.
E1-10 asks whether and how carbon pricing is applied in decision-making and the average price per tonne for each scheme.
Read the credit disclosures
¶34 asks for the amount of credits “verified against recognised quality standards for carbon credits and cancelled in the reporting period”, the amount purchased and not yet cancelled, and the share from removal projects.
¶35 applies where the undertaking has made public claims of GHG neutrality that involve carbon credits.
¶37(a) also asks about the consistency of internal carbon prices with those used in the financial statements for impairment tests.
- 1
Removals in the value chain
Projects, amounts removed and stored, non-permanence and reversals (¶33).
- 2
Credits outside it
Credits cancelled in the period, purchased and not yet cancelled, and the removal share (¶34).
- 3
Neutrality claims
How claims relying on credits neither hinder nor undermine the targets (¶35).
- 4
Internal carbon price
How it is used in decisions, and the average price per tonne (¶37).
E1-11
Anticipated financial effects, phased in
E1-11 asks how material climate risks and opportunities are expected to affect financial position and performance.
It is phased in, but the carrying amounts of assets at material physical and transition risk, ¶39(a)(b) and ¶40(a)(b), are excepted from the reliefs.
Read the phase-in paragraphs
ESRS 1 ¶127 lets “other undertakings”, first reporting from FY2027, omit all anticipated-financial-effects information for their first two financial years and the quantitative part for their first four.
Wave-one undertakings above €450 million and 1,000 employees may omit it for financial years before 2028, and the quantitative part before 2030 (¶125).
Both reliefs carry the same exception: “ESRS E1-11 paragraph 39(a)(b) and 40(a)(b)”.
¶41 asks for the methodology behind the amounts, including whether it uses the scenario analysis used to identify transition risks.
E1-11 and its reliefsExplore
Module 01 / 04
Physical risk
Assets at material physical risk, the share covered by adaptation, revenue at risk (¶39).
Module 02 / 04
Transition risk
Assets at risk, stranded-asset range on a 1.5 °C scenario, collateral, unrecognised liabilities, revenue (¶40).
Module 04 / 04
Relief
First-time reporters: all AFE two years, quantitative four, except ¶39(a)(b) and ¶40(a)(b) (ESRS 1 ¶127).
When
ESRS E1 dates, from adoption to first reports
The revised E1 is in a published regulation that is not yet in force on 11 October 2026.
- 31 July 202301
- 3 July 202602
- 21 September 202603
- 10 November 202604
- FY202605
Three options
The 2023 ESRS as amended, those with eight reliefs, or the revised ESRS; state which. - FY2027 onwards06
The UK view
ESRS E1 against UK SRS S2: close, not the same
The joint ESRS–ISSB interoperability guidance says “almost all the disclosures in ISSB Standards related to climate are included in ESRS”.
That is not the converse: E1 asks for more in places, and UK SRS S2 asks for things E1 makes optional.
Read the comparison
| Point | ESRS E1 | UK SRS S2 |
|---|---|---|
| Scenario analysis | Only if used (¶17, AR 6) | Required (¶22) |
| Resilience assessment | Not required annually (AR 9) | Annually (¶B18) |
| Scope 2 | Location-based and market-based (¶30(a)(ii)) | Location-based (¶29(a)(v), ¶B30) |
| Materiality | Double: impact or financial | Single (financial) materiality |
| When | FY2027 for CSRD reporters | Comply or explain for listed companies from periods beginning 1 January 2027 |
The guidance is dated 2 May 2024 and maps 2023 paragraph numbers, so check any mapping against the revised text; the detail is on ESRS–ISSB interoperability.
The ISSB original is on IFRS S2, and the wider comparison on the ESRS and UK SRS compared.
Where they differExplore
Module 04 / 04
Materiality
E1: double. UK SRS S2: single (financial) materiality to primary users.
Who reports
Which companies report under ESRS E1
E1 applies to undertakings in CSRD scope, which from FY2027 means exceeding both €450 million net turnover and an average of 1,000 employees.
A UK group meets E1 only through an EU entity or listing in scope; the routes are on CSRD and UK SRS.
Read the scope detail
The threshold is in Article 19a(1) of the consolidated Accounting Directive as amended by Directive (EU) 2026/470.
The post-Omnibus picture is on the CSRD after Omnibus I.
Scope firstExplore
Module 01 / 04
From FY2027
Undertakings exceeding both €450 million net turnover and 1,000 employees.
Module 03 / 04
Wave one
FY2024–FY2026 reporters fall outside from FY2027 unless they meet the new test.
Illustrative example
An ESRS E1 statement, in outline
An invented EU manufacturing subsidiary of a UK group, in CSRD scope from FY2027, which concluded that climate mitigation and energy are material and adaptation is not.
Illustrative only; not a finding about any company.
- 01 / Materiality01
Conclude on the sub-topics
Mitigation and energy material; adaptation not, with the basis recorded for IRO-1 and IRO-2. - 02 / E1-102
Describe the plan
Key features, assumptions and progress, or a statement that no plan with those features exists yet. - 03 / E1-603
State gross targets
Absolute Scope 1–3 targets; a statement on 1.5 °C compatibility; no credits counted. - 04 / E1-7, E1-804
Report energy and emissions
MWh by source; Scope 1, location- and market-based Scope 2, significant Scope 3 categories. - 05 / E1-1105
Use the relief, keep the exception
Omit AFE in the first two years, but report ¶39(a)(b) and ¶40(a)(b).
What it skips
Adaptation-only disclosures, because ESRS 1 ¶30 limits reporting to the material sub-topic.
What it reuses for UK SRS
The Scope 1 and location-based Scope 2 figures; UK SRS S2 still needs its scenario analysis and annual resilience assessment.
What goes wrong
Six ESRS E1 mistakes
Treating E1 as automatic
It is reported where climate is material (¶2), even if that is usually the outcome.
Netting credits
Targets are gross; credits and removals are disclosed under E1-9 (AR 12).
One Scope 2 figure
E1 asks for both location-based and market-based (¶30(a)(ii)).
Assuming scenario analysis is required
Only if used (¶17, AR 6) — unlike UK SRS S2.
Forgetting the AFE exception
¶39(a)(b) and ¶40(a)(b) are outside the phase-in reliefs.
Citing 2023 paragraph numbers
The revision replaced the Annex; cite the revised E1.
Related reading
The datapoint count for E1, on EFRAG’s draft basis, is on ESRS datapoints, and how climate impacts, risks and opportunities are identified is on impacts, risks and opportunities.
The other topical guides in this series are ESRS S1 own workforce, and the scope and dates are on CSRD thresholds and the CSRD timeline.
Frequently asked
Questions people ask
What is ESRS E1?
ESRS E1 Climate Change is the EU’s topical standard for climate disclosures under the CSRD.
In its revised form, published as Delegated Regulation (EU) 2026/1563, it has eleven disclosure requirements, E1-1 to E1-11, covering climate change mitigation, climate change adaptation and energy.
Is ESRS E1 mandatory for every CSRD reporter?
Only where climate relates to material impacts, risks or opportunities. ¶2 says the statement provides E1 information “if this topic relates to material impacts, risks and opportunities”, and if not every sub-topic is material, ESRS 1 ¶30 limits reporting to the material sub-topic.
When does the revised ESRS E1 apply?
To financial years beginning on or after 1 January 2027.
For a financial year starting in 2026 an undertaking may use the 2023 ESRS as amended, those standards with eight reliefs, or the revised ESRS in full, and must state which.
How many disclosure requirements does ESRS E1 have?
Eleven: transition plan (E1-1), climate-related risks and scenario analysis (E1-2), resilience (E1-3), policies (E1-4), actions and resources (E1-5), targets (E1-6), energy (E1-7), gross Scope 1, 2 and 3 emissions (E1-8), removals and carbon credits (E1-9), internal carbon pricing (E1-10) and anticipated financial effects (E1-11).
Does ESRS E1 require a transition plan?
It requires information about one. ¶12 sets out what the description includes, and ¶13 says that if the undertaking has no transition plan with the key features listed, it must disclose that fact and indicate whether and, if so, when it expects to adopt one.
Does ESRS E1 require climate scenario analysis?
No. ¶17 applies “if climate-related scenario analysis is used”, and AR 6 says the undertaking “may use” it.
UK SRS S2, by contrast, requires scenario analysis.
Does ESRS E1 require an annual resilience analysis?
No. AR 9 says an undertaking “is not required to perform an analysis of climate resilience on an annual basis”, though it must update the analysis when it updates its assessment of climate-related impacts, risks and opportunities.
UK SRS S2 ¶B18 requires an annual resilience assessment.
Which Scope 2 method does ESRS E1 require?
Both. ¶30(a)(ii) requires Scope 2 emissions “location-based and market-based”.
UK SRS S2 requires location-based Scope 2 and does not require market-based.
Which Scope 3 categories must be reported under ESRS E1?
Each significant Scope 3 category, as a total and per category (¶30(a)(iii)).
AR 24 asks the undertaking to screen against the GHG Protocol’s 15 categories, or the EN ISO 14064-1 categories, and to identify significant ones by magnitude and criteria such as financial spend, influence, transition risks and opportunities or stakeholder views.
Can carbon credits count towards ESRS E1 targets?
No. AR 12 says GHG emission reduction targets are gross targets and must not include GHG removals, carbon credits or avoided emissions as means of achieving them.
Credits are disclosed separately under E1-9.
Which consolidation boundary does ESRS E1 use for emissions?
Financial control as per the GHG Protocol Corporate Standard by default.
AR 19 says the undertaking may alternatively use the equity share or operational control approach.
When must anticipated financial effects under E1-11 be reported?
They are phased in.
Under ESRS 1 ¶127 a first-time reporter from FY2027 may omit them for its first two years and the quantitative part for its first four, except E1-11 ¶39(a)(b) and ¶40(a)(b).
Wave-one undertakings have dated reliefs to 2028 and 2030 under ¶¶125–126.
How many datapoints does ESRS E1 have?
EFRAG’s draft list of 28 August 2026 counts 84 “shall” datapoints in E1, excluding the policy, action, target and metric datapoints of ESRS 2, and every one is subject to materiality. It is a draft, non-authoritative count.
Does reporting under ESRS E1 satisfy UK SRS S2?
Not automatically.
The joint guidance says almost all ISSB climate disclosures are included in the ESRS, but UK SRS S2 asks for things E1 does not, such as required scenario analysis and an annual resilience assessment.
A group reporting under both needs a reconciliation.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 13 sources fromEUR-LexCouncil of the EUEuropean CommissionEFRAGDepartment for Business and TradeIFRS Foundation / EFRAG
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — Annex I, ESRS E1 ¶¶1–42 and AR 1–AR 24; ESRS 1 ¶¶122–127
The published standard; applies to financial years beginning on or after 1 January 2027.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first set of ESRS
The 2023 E1, still one of the FY2026 options.
- Council of the EUC(2026) 5010 final, Annex I — the revised ESRS as transmitted
The same text before publication.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Art 19a and Art 29a
Who reports: undertakings above €450 million net turnover and 1,000 employees from FY2027.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
The scope change in force since 18 March 2026.
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
The adoption announcement.
- EFRAGESRS Knowledge Hub — revised ESRS E1 (delegated-act rendering)
EFRAG’s navigable rendering of the same text.
- EFRAGESRS Knowledge Hub — revised ESRS 2 (IRO-1, IRO-2, SBM-3)
Where the materiality conclusion on climate is disclosed.
- EFRAG2026 Draft List of Datapoints — Explanatory Note, Figures 1 and 2
EFRAG’s draft count: 84 “shall” datapoints in E1, all subject to materiality.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — ¶22, ¶29(a)(v), ¶B18, ¶B30
The UK climate standard: scenario analysis, annual resilience and location-based Scope 2.
- IFRS Foundation / EFRAGESRS–ISSB Standards Interoperability Guidance, 2 May 2024
Almost all ISSB climate disclosures are included in the ESRS; mapped to the 2023 numbering.
- GHG ProtocolA Corporate Accounting and Reporting Standard (Revised Edition, 2004)
The boundary approaches E1 AR 19 refers to.
- GHG ProtocolCorporate Value Chain (Scope 3) Accounting and Reporting Standard (2011)
The 15 categories E1 AR 24 screens against.
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