ESRS E1 Climate Change — What Your Company Must Disclose

What Is ESRS E1?

ESRS E1 “Climate change” is one of the topical standards in the European Sustainability Reporting Standards (ESRS), adopted as Commission Delegated Regulation (EU) 2023/2772 (CELEX 32023R2772). It applies to companies required to report under the Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464, CELEX 32022L2464) and for whom climate change is a material topic.

E1 contains 9 disclosure requirements (E1-1 through E1-9), covering transition plans, policies, actions, targets, energy, the Scope 1/2/3 GHG inventory, removals and carbon credits, internal carbon pricing, and the anticipated financial effects of climate risk. Together they form the climate chapter of your sustainability statement. Below, every requirement is tied to its controlling paragraph in the standard so the disclosure can be reconstructed from the source text.

Who Must Report — and When?

E1 is produced by companies in scope of the CSRD, which phases in by company size. The “stop-the-clock” Directive (EU) 2025/794 (CELEX 32025L0794) postponed the second and third waves by two years. The table reflects the post-amendment timeline:

The postponement is the operative effect of the amendment, which replaces the application dates in the CSRD:

“in point (b), the introductory wording is replaced by the following: ‘for financial years starting on or after 1 January 2027:’… in point (c), the introductory wording is replaced by the following: ‘for financial years starting on or after 1 January 2028:’”
— Directive (EU) 2025/794, Article 1, CELEX 32025L0794. Retrieved 2026-06-04 from EUR-Lex.

Materiality gate: E1 only applies if your company has determined that climate change is a material impact, risk, or opportunity through a double-materiality assessment. If climate is not material, you must disclose that conclusion and the reasoning behind it. ESRS E1 builds the topical standard on top of the cross-cutting General Disclosures (ESRS 2), and a company without a material climate topic still has to explain why.

The 9 Disclosure Requirements

The paragraph numbers below are the controlling paragraphs of ESRS E1 in CELEX 32023R2772; “AR” references are the Application Requirements in the same standard. Each requirement starts with the verbatim obligation so the disclosure can be reconstructed from the source.

E1-1 — Transition plan for climate change mitigation

ESRS E1 par. 14–16. Disclose a transition plan, and explain its objective:

“The objective of this Disclosure Requirement is to enable an understanding of the undertaking’s past, current, and future mitigation efforts to ensure that its strategy and business model are compatible with the transition to a sustainable economy, and with the limiting of global warming to 1.5 °C in line with the Paris Agreement and with the objective of achieving climate neutrality by 2050…”
— ESRS E1, paragraph 15, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Par. 16 requires the plan to spell out the decarbonisation levers and key actions, an explanation and quantification of the investments and funding supporting it (cross-referenced to taxonomy-aligned CapEx), and a qualitative assessment of locked-in GHG emissions from key assets and products.

E1-2 — Policies related to climate change

ESRS E1 par. 22–25. Describe the policies adopted to manage material climate impacts, risks and opportunities:

“The undertaking shall describe its policies adopted to manage its material impacts, risks and opportunities related to climate change mitigation and adaptation.”
— ESRS E1, paragraph 22, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Par. 25 requires the company to indicate whether and how its policies address climate change mitigation, climate change adaptation, energy efficiency, renewable-energy deployment, and other areas.

E1-3 — Actions and resources

ESRS E1 par. 26–29. Disclose the concrete actions and the resources allocated to them:

“The undertaking shall disclose its climate change mitigation and adaptation actions and the resources allocated for their implementation.”
— ESRS E1, paragraph 26, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Par. 29 requires actions to be presented by decarbonisation lever, the achieved and expected GHG reductions to be included, and significant CapEx/OpEx amounts to be related to the relevant line items or notes in the financial statements.

E1-4 — Targets

ESRS E1 par. 30–34. Disclose your climate-related targets:

“The undertaking shall disclose the climate-related targets it has set.”
— ESRS E1, paragraph 30, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Par. 34 sets the detail: targets are disclosed in absolute value (and where relevant intensity value), cover Scopes 1, 2 and 3 (separately or combined), and are gross targets that exclude removals, carbon credits and avoided emissions. They must reach at least to 2030:

“GHG emission reduction targets shall at least include target values for the year 2030 and, if available, for the year 2050. From 2030, target values shall be set after every 5-year period thereafter.”
— ESRS E1, paragraph 34(d), CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

E1-5 — Energy consumption and mix

ESRS E1 par. 35–39. Report total energy consumption and its mix. Par. 37 requires the total in MWh related to own operations, disaggregated by:

• total energy consumption from fossil sources;
• total energy consumption from nuclear sources; and
• total energy consumption from renewable sources — itself split into renewable fuel, purchased renewable electricity/heat/steam/cooling, and self-generated non-fuel renewable energy.

Companies with operations in high-climate-impact sectors must further break fossil consumption down by coal, crude oil/petroleum, natural gas, other fossil sources, and purchased fossil-sourced electricity/heat/steam/cooling (par. 38). Par. 39 requires non-renewable and renewable energy production to be disclosed separately in MWh where applicable.

E1-6 — Gross Scope 1, 2, and 3 GHG emissions

ESRS E1 par. 44–55. This is the core quantitative disclosure. The umbrella obligation is par. 44:

“The undertaking shall disclose in metric tonnes of CO2eq its: (a) gross Scope 1 GHG emissions; (b) gross Scope 2 GHG emissions; (c) gross Scope 3 GHG emissions; and (d) total GHG emissions.”
— ESRS E1, paragraph 44, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Each figure then has its own detailed paragraph:

• Scope 1 — par. 48 — gross Scope 1 emissions, plus “the percentage of Scope 1 GHG emissions from regulated emission trading schemes” (par. 48(b)).
• Scope 2 — par. 49 — both “the gross location-based Scope 2 GHG emissions” and “the gross market-based Scope 2 GHG emissions” (par. 49(a)–(b)).
• Scope 3 — par. 51 — emissions “from each significant Scope 3 category (i.e. each Scope 3 category that is a priority for the undertaking)”.
• Total — par. 52 — the sum of Scopes 1, 2 and 3, disaggregated by location-based versus market-based Scope 2.

All figures are reported in metric tonnes of CO₂-equivalent. The methodology is fixed by AR 39, which requires the inventory to “include emissions of CO2, CH4, N2O, HFCs, PFCs, SF6, and NF3” (AR 39(c)) and to “use the most recent Global Warming Potential (GWP) values published by the IPCC based on a 100-year time horizon” (AR 39(d)). Prior-period comparative information is required for quantitative metrics under ESRS 1 par. 83. A first-year relief is available to smaller companies:

“Undertakings or groups not exceeding on their balance sheet dates the average number of 750 employees during the financial year (on a consolidated basis where applicable) may omit the datapoints on scope 3 emissions and total GHG emissions for the first year of preparation of their sustainability statement.”
— ESRS 1, Appendix C (List of phased-in Disclosure Requirements), ESRS E1-6 row, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

E1-7 — GHG removals and carbon credits

ESRS E1 par. 56–61. Disclose removals you have achieved and the credits you have financed:

“The undertaking shall disclose: (a) GHG removals and storage in metric tonnes of CO2eq resulting from projects it may have developed in its own operations, or contributed to in its upstream and downstream value chain; and (b) the amount of GHG emission reductions or removals from climate change mitigation projects outside its value chain it has financed or intends to finance through any purchase of carbon credits.”
— ESRS E1, paragraph 56, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Where a net-zero target is claimed in addition to gross reduction targets, par. 60 requires the residual emissions intended to be neutralised — “after approximately 90-95% of GHG emission reduction” — to be explained.

E1-8 — Internal carbon pricing

ESRS E1 par. 62–63. An opt-in disclosure — required only if you actually apply an internal carbon price:

“The undertaking shall disclose whether it applies internal carbon pricing schemes, and if so, how they support its decision making and incentivise the implementation of climate-related policies and targets.”
— ESRS E1, paragraph 62, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

Par. 63 requires the type of scheme (shadow price, internal fee, internal fund), its scope of application, the carbon prices applied with the critical assumptions, and the approximate gross emission volumes by Scope covered by the scheme.

E1-9 — Anticipated financial effects

ESRS E1 par. 64–69. Disclose the anticipated financial effects of material physical risks, transition risks, and the potential to benefit from climate-related opportunities:

“The undertaking shall disclose its: (a) anticipated financial effects from material physical risks; (b) anticipated financial effects from material transition risks; and (c) potential to benefit from material climate-related opportunities.”
— ESRS E1, paragraph 64, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

E1-9 carries a phase-in. A company may omit it entirely in the first year, and may meet it with qualitative-only disclosures for the first three years where quantitative figures are impracticable:

“The undertaking may omit the information prescribed by ESRS E1-9 for the first year of preparation of its sustainability statement. The undertaking may comply with ESRS E1-9 by reporting only qualitative disclosures for the first 3 years of preparation of its sustainability statement, if it is impracticable to prepare quantitative disclosures.”
— ESRS 1, Appendix C (List of phased-in Disclosure Requirements), ESRS E1-9 row, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.

How BARGO applies this

BARGO applies the requirements above through its compliance tooling, Unbin. The points below describe that tooling, not BARGO’s research.

Unbin automates the data-intensive parts of E1 compliance:

• E1-5 and E1-6 are calculated automatically from your activity data using ~50,065 emission factors across 12 factor sets.
• E1-1 and E1-4 are supported by the transition plan modeller, which produces reduction levers and targets with CapEx/OpEx projections.
• E1-2, E1-3, E1-7, E1-8, E1-9 are drafted by AI using your actual emissions data as grounded input — every number in the output is validated against your data, never hallucinated.
• The three-signature assurance workflow (preparer → reviewer → approver) gates every disclosure before publication.
• Every calculation includes a Data Quality Rating per EF 3.1 Annex I and an immutable audit snapshot.

Frequently Asked Questions

How many disclosure requirements does ESRS E1 have?

Nine, labelled E1-1 through E1-9: transition plan (par. 14–16), policies (par. 22–25), actions and resources (par. 26–29), targets (par. 30–34), energy consumption and mix (par. 35–39), gross Scope 1/2/3 and total GHG emissions (par. 44–55), GHG removals and carbon credits (par. 56–61), internal carbon pricing (par. 62–63), and anticipated financial effects (par. 64 onward). All are in ESRS E1 under CELEX 32023R2772.

Which paragraph actually requires Scope 1, Scope 2 and Scope 3?

The umbrella requirement is paragraph 44, which requires all four figures — gross Scope 1, gross Scope 2, gross Scope 3 and total — in metric tonnes of CO₂e. The detailed breakdowns then live in separate paragraphs: Scope 1 in par. 48 (with the percentage from regulated emission-trading schemes), Scope 2 in par. 49 (both location-based and market-based), Scope 3 in par. 51 (per significant category), and the total in par. 52. (ESRS E1, CELEX 32023R2772.)

Can a smaller company skip Scope 3?

Only for the first year, and only below a size line. A company or group not exceeding an average of 750 employees during the financial year “may omit the datapoints on scope 3 emissions and total GHG emissions for the first year of preparation” of its sustainability statement (ESRS 1, Appendix C, E1-6 row, CELEX 32023R2772). After the first year, Scope 3 for significant categories is required.

Which gases and which global-warming-potential values must I use?

The seven Kyoto-basket gases. AR 39(c) requires the inventory to “include emissions of CO2, CH4, N2O, HFCs, PFCs, SF6, and NF3”, with additional gases where significant, and AR 39(d) requires the “most recent Global Warming Potential (GWP) values published by the IPCC based on a 100-year time horizon” for converting non-CO₂ gases to CO₂-equivalent (ESRS E1, CELEX 32023R2772).

Is E1-9 (financial effects) required from day one?

No. A company “may omit the information prescribed by ESRS E1-9 for the first year”, and may report “only qualitative disclosures for the first 3 years” where quantitative figures are impracticable (ESRS 1, Appendix C, E1-9 row, CELEX 32023R2772).

Did the 2025 simplification change when ESRS E1 applies?

It changed the timing of the CSRD waves, not the content of E1. Directive (EU) 2025/794 (CELEX 32025L0794) replaced the CSRD application dates so that the second wave applies for financial years starting on or after 1 January 2027 and the third wave from 1 January 2028 — a two-year postponement. The E1 disclosure requirements themselves are unchanged by that amendment.

Legal References

• ESRS Set 1 (incl. ESRS 1 and ESRS E1 “Climate change”) — Commission Delegated Regulation (EU) 2023/2772, CELEX 32023R2772. Retrieved 2026-06-04 from EUR-Lex.
• CSRD — Directive (EU) 2022/2464 amending Directives 2013/34/EU, 2004/109/EC, 2006/43/EC, and Regulation (EU) No 537/2014, CELEX 32022L2464. Retrieved 2026-06-04 from EUR-Lex.
• “Stop-the-clock” amendment — Directive (EU) 2025/794, CELEX 32025L0794. Retrieved 2026-06-04 from EUR-Lex.
• GHG Protocol Corporate Standard (version 2004) — referenced as the GHG accounting basis by ESRS E1 AR 39(a).
• ESRS 1, Appendix C — List of phased-in Disclosure Requirements (Scope 3 / total GHG first-year relief; E1-9 phase-in).