ESRS E1 Climate change: Disclosure Requirements, Datapoints and What Changes in the Simplified ESRS

The CSRD is Directive (EU) 2022/2464 of 14 December 2022, and E1 gives its reporting duty a climate content; the duty as a whole is set out where the Corporate Sustainability Reporting Directive (CSRD) is explained.

The ESRS are delegated regulations, so they are binding and apply directly in every Member State without transposition. The Commission adopts them by delegated act and takes the technical advice of EFRAG into consideration (Article 49(3b) of Directive 2013/34/EU).

The sections below cover content, materiality, versions, the disclosure requirements of both sets, the changes and preparation. The table gives the key points of both versions as of 29 October 2026.

What ESRS E1 Covers

ESRS E1 covers how an undertaking affects the climate and how climate change affects it, through three sub-topics, seven greenhouse gases and a set of disclosure requirements on strategy, risks, policies, targets and metrics. The metrics range from energy consumption and gross emissions to removals, carbon credits, internal carbon pricing and anticipated financial effects. E1 is one of the 12 standards in both versions, and its place among the others is shown under ESRS, the 12 European Sustainability Reporting Standards.

Climate Change Mitigation, Adaptation and Energy

The three sub-topics of E1 are climate change mitigation, climate change adaptation and energy (ESRS 1 AR 16 in the 2023 set; ESRS 1 Appendix A in the 2026 set). Energy has its own metric disclosure requirement: energy consumption and mix, measured in MWh and split into fossil, nuclear and renewable sources. Climate-linked remuneration sits outside E1, under ESRS 2 GOV-3 in the 2023 set and under ESRS 2 GOV-2 in the 2026 set.

Seven Greenhouse Gases and the Legal Basis in Article 29b

E1 covers seven greenhouse gases: CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3 (E1 para 4 in the 2023 set; para 10(a) in the 2026 set). Other air emissions stay out of E1: ozone-depleting substances, NOx and SOx are reported under ESRS E2 Pollution (2023 set, E1 para 8). Article 29b(2)(a)(i) of Directive 2013/34/EU, as inserted by Directive (EU) 2022/2464, requires the standards to specify information on climate change mitigation, "including as regards scope 1, scope 2 and, where relevant, scope 3 greenhouse gas emissions", and point (ii) adds climate change adaptation.

When E1 Applies: Materiality and the Non-Material Explanation

E1 applies when climate change is material for the undertaking, and an undertaking that omits all E1 disclosure requirements must still explain why it concluded that climate change is not material. A sustainability matter is material when it meets the impact materiality criteria, the financial materiality criteria, or both (ESRS 1 para 28 of the 2023 set). The method for testing climate change against both criteria is the double materiality assessment under the ESRS.

The 2026 set adds a ban: ESRS-prescribed information that is not material "shall not" be disclosed, except supplementary information under section 8.2 (ESRS 1 para 24). E1 binds only undertakings that report under Article 19a or Article 29a of Directive 2013/34/EU.

Explaining Why Climate Change Is Not Material

The explanation differs by set: the 2023 set asks for a detailed explanation with a forward-looking analysis of conditions that could make climate change material, and the 2026 set asks only for the basis for concluding that it is not material. In the 2023 set the rule sits in ESRS 1 para 32 and ESRS 2 IRO-2 and applies when all E1 disclosure requirements are omitted.

Under the 2026 set, ESRS 2 paragraph 37(b) (IRO-2) of Delegated Regulation (EU) 2026/1563 requires the undertaking to disclose "the basis for concluding that climate change is not material, if the undertaking has reached this conclusion and therefore omits all DRs in ESRS E1 Climate Change".

Which Version Applies to Which Financial Year

The 2023 set applies to financial years beginning on or after 1 January 2024, the 2026 set to financial years beginning on or after 1 January 2027, and for financial years beginning in 2026 the undertaking chooses. Delegated Regulation (EU) 2023/2772 of 31 July 2023 was published on 22 December 2023, and the quick fix, Delegated Regulation (EU) 2025/1416, replaced its phase-in appendix from financial year 2025. Delegated Regulation (EU) 2026/1563 of 3 July 2026, published on 21 September 2026, enters into force on 10 November 2026 (Article 3) and replaces Annexes I and II of the 2023 act without repealing it (Article 1). The Official Journal texts are the law; EFRAG's drafts and advice are not. Each act is described under the delegated acts behind each ESRS version.

For financial years beginning in 2026, Article 2(1) of Delegated Regulation (EU) 2026/1563 offers the 2023 set as last amended by Delegated Regulation (EU) 2025/1416, the 2026 set, or the 2023 set with eight listed ESRS 1 reliefs (paragraphs 27, 32 to 33, 74 to 75, 90, 91, 92, 106 and 110). The sustainability statement states which version it applies (Article 2(2)).

Phase-In Reliefs for Anticipated Financial Effects

In the 2026 set the only E1 phase-in concerns anticipated financial effects under E1-11, and paragraphs 39(a), 39(b), 40(a) and 40(b) are never phased in. Wave-one undertakings (ESRS 1 para 122) may omit all anticipated financial effects for financial years before 2028 and the quantitative ones for financial years before 2030 (ESRS 1 paras 125 and 126, points (b) and (c)). Other undertakings may omit all of them for their first two financial years and the quantitative ones for their first four (ESRS 1 para 127, points (b) and (c)).

The 2023 set lets undertakings omit E1-9 in the first year and give qualitative information only for the first three years where quantitative information is impracticable (ESRS 1 Appendix C). Delegated Regulation (EU) 2025/1416 lets wave-one undertakings omit E1-9 for their first three years. The 2026 set contains no scope 3 phase-in in ESRS 1 paras 121 to 127. The reliefs of all 12 standards are listed under ESRS phase-in provisions for every standard.

The E1 Disclosure Requirements in Both Versions

The 2026 set has 11 E1 disclosure requirements, E1-1 to E1-11, against 9 in the 2023 set, because two risk and resilience disclosures that sat under ESRS 2 in the 2023 set became E1-2 and E1-3. The codes therefore shift. E1-5 is energy consumption and mix in the 2023 set but actions and resources in the 2026 set; E1-7 moves from removals and carbon credits to energy; E1-9 moves from anticipated financial effects to removals and carbon credits.

A code without its set is ambiguous, so every document should name both. Two disclosure requirements have their own pages: the transition plan (E1-1 in both sets) and gross GHG emissions (E1-6 in the 2023 set, E1-8 in the 2026 set). The table maps all 11 codes of the 2026 set to their 2023 source.

Risks, Scenario Analysis and Resilience

In the 2026 set, E1-2 asks how the undertaking identifies climate-related risks and uses scenario analysis (paras 14 to 17, AR 6), and E1-3 asks how resilient its strategy and business model are (paras 18, 19, AR 7 to AR 10). Under the 2023 set, IRO-1 in E1 (paras 20 and 21) asks for physical risks "considering at least high emission climate scenarios" and for transition risks considering a 1.5°C scenario with no or limited overshoot. SBM-3 in E1 contributes its para 18 to E1-2 and its resilience analysis in para 19 to E1-3.

Policies, Actions and Targets

Policies, actions and targets are E1-4, E1-5 and E1-6 in the 2026 set (paras 20 to 24) and E1-2, E1-3 and E1-4 in the 2023 set (paras 22 to 34). Targets are gross in both sets: they do not include GHG removals, carbon credits or avoided emissions (2026 set AR 12; 2023 set para 34(b)). The 2026 set asks for a 1.5°C-aligned reference target value for scope 1 and 2 and a separate one for scope 3 where scope 3 targets exist (AR 17). The 2023 set sets target years of at least 2030 and, if available, 2050, with targets every five years from 2030 (para 34(c) and (d)).

The general content follows ESRS 2: the minimum disclosure requirements of the 2023 set (MDR-P, MDR-A, MDR-M and MDR-T, ESRS 2 paras 60 to 81) are renamed general disclosure requirements in the 2026 set (GDR-P, GDR-A, GDR-M and GDR-T, ESRS 2 paras 38 to 52). The shared content is explained under general disclosure requirements for policies, actions and targets.

Energy Consumption and Mix

Energy consumption and mix is E1-5 in the 2023 set (paras 35 to 43) and E1-7 in the 2026 set (paras 25 to 28, AR 18), reported in MWh and split into fossil, nuclear and renewable sources. Both sets ask for a breakdown of fossil energy consumption for undertakings in high climate impact sectors. Both also cover energy production: the 2026 set asks for renewable and non-renewable energy production where the undertaking produces energy.

GHG Removals, Carbon Credits and Internal Carbon Pricing

Removals and carbon credits are E1-7 in the 2023 set (paras 56 to 61) and E1-9 in the 2026 set (paras 32 to 35, AR 27, AR 28), and internal carbon pricing is E1-8 (paras 62, 63) and then E1-10 (paras 36, 37). In the 2023 set, a net-zero target leaves residual emissions after an approximately 90 to 95 % reduction of GHG emissions, with justified sectoral variations (para 60). In the 2026 set, E1-10 para 37 asks whether and how carbon prices are applied in decision-making, whether they are consistent with the prices used in impairment tests, and the average carbon price per tonne for each scheme.

Anticipated Financial Effects

Anticipated financial effects from material physical and transition risks and material climate-related opportunities are E1-11 in the 2026 set (paras 38 to 42, AR 29 to AR 32) and E1-9 in the 2023 set (paras 64 to 70). In the 2026 set only climate keeps its own disclosure requirement for anticipated financial effects: the other environmental standards report them through ESRS 2 para 27, and the separate E2-6, E3-5, E4-6 and E5-6 exist only in the 2023 set. The time horizons are the same in both sets: the reporting period for the short term, up to five years for the medium term and more than five years for the long term (2023 set ESRS 1 para 77; 2026 set para 79).

What Delegated Regulation (EU) 2026/1563 Changes in E1

Delegated Regulation (EU) 2026/1563 restructures E1 into 11 disclosure requirements, removes metric datapoints such as energy intensity and total GHG emissions and adds new ones on carbon credits and financial effects, for financial years beginning on or after 1 January 2027. Recital 3 of Delegated Regulation (EU) 2026/1563 lists the points on which the Commission departed from EFRAG's technical advice; they include (v) anticipated financial effects, (vi) greenhouse gas emissions and (vii) climate transition plans. The changes to the other standards are set out under what Delegated Regulation (EU) 2026/1563 changes across all 12 ESRS.

The table compares the two sets item by item.

According to the Commission (3 July 2026), the revised ESRS reduce mandatory datapoints by over 60 % and total datapoints by over 70 %, and are expected to cut reporting costs by more than 30 % per company.

GHG and Energy Datapoints Removed or Moved

The 2026 set drops energy intensity per net revenue and the renewable sub-split from the energy disclosure, and total GHG emissions and GHG intensity per net revenue from the gross emissions disclosure. The 2023 E1-5 splits renewable energy into fuels, purchased and self-generated energy (paras 37 to 43); the 2026 E1-7 keeps only the fossil, nuclear and renewable split. Climate-linked remuneration moves to ESRS 2 GOV-2.

E1-8 of the 2026 set still asks for scope 1 emissions with the share from the EU ETS, scope 2 on a location-based and a market-based basis and scope 3 for each significant category (para 30). It adds direct biogenic CO2 emissions, reported separately (para 31). The calculation method is explained under scope 1, 2 and 3 GHG emissions under E1-8.

Datapoints Added in the 2026 Set

The 2026 set adds carbon-credit datapoints to E1-9 and three new datapoints to E1-11. E1-9 now asks for carbon credits purchased in the period and not yet cancelled, the share of credits from removal projects split into nature-based and technological removals, and the non-permanence and reversals of removal projects (paras 33 and 34). Removals are accounted for with consensus methods such as Regulation (EU) 2024/3012 (AR 27(a)).

E1-11 adds the range of estimated potential stranded assets in the medium and long term based on a 1.5°C scenario (para 40(a)), real estate assets used as loan collateral broken down by energy-efficiency class (para 40(c)), and the amount of assets or revenue related to climate-related opportunities (para 42).

How to Prepare the E1 Disclosures

Prepare E1 in seven steps, in this order, and record for each step which set and which paragraph you followed. The steps are listed below.

1. Confirm that the undertaking reports under the CSRD, for example with the CSRD scope check.

2. Choose the set for the financial year and state it in the sustainability statement (Article 2(2) of Delegated Regulation (EU) 2026/1563).

3. Assess whether climate change is material, or prepare the non-material explanation of the chosen set.

4. Map the E1 disclosure requirements with the crosswalk table, using only the codes of the chosen set.

5. Collect energy and GHG data; information that may be required from value-chain undertakings with up to 1,000 employees "only comprises the datapoints specified in Annex II to Commission Delegated Regulation (EU) 2026/1560" (2026 set ESRS 1 para 66), the value-chain cap for suppliers with up to 1,000 employees.

6. Reconcile, for the 2023 set, the E1-1 investments with the Taxonomy CapEx KPIs (para 16(c)), as described under EU Taxonomy reporting in the sustainability statement.

7. Plan for the limited assurance of the sustainability statement, the only assurance level under Article 34(1)(aa) of Directive 2013/34/EU as replaced by Directive (EU) 2026/470.

ESMA's 2026 European Common Enforcement Priorities (13 October 2026) focus FY2026 enforcement of connected information on ESRS E1 Climate change and S1 Own workforce, because these topics are more mature; the first priority is continued progress in applying the materiality assessment.

For the steps across all standards, see our CSRD compliance plan.

How E1 Connects to Other Frameworks

E1 overlaps with IFRS S2, the ISSB's climate standard, and the joint interoperability guidance of EFRAG and the IFRS Foundation maps the two using paragraph numbers of the 2023 set. The ESRS-ISSB interoperability guidance of 2 May 2024 states that the standards were developed "to achieve a high degree of alignment of the respective standards, with a specific focus on climate-related reporting" and that "almost all the disclosures in ISSB Standards related to climate are included in ESRS". Where E1 para 50 and IFRS S2 differ, "two different disaggregations would need to be provided", and according to the guidance energy consumption and mix (E1-5 of the 2023 set) has no ISSB counterpart (Table 4.2.2). The full comparison is set out under ESRS and ISSB frameworks compared.

E1 also draws on the GHG Protocol Corporate Standard (2004) for the reporting boundary, with financial control as the default and equity share or operational control as alternatives (2026 set E1 AR 19); ESRS requirements take precedence over GHG accounting standards (AR 20(a)).

E1 Questions

Four questions recur about ESRS E1.

Is ESRS E1 mandatory?

Only when climate change is material: an undertaking reporting under the ESRS includes E1 if climate change is material and, if it omits all E1 disclosure requirements, explains its conclusion. The 2023 set asks for a detailed explanation with a forward-looking analysis, the 2026 set for the basis for that conclusion.

How many disclosure requirements does E1 have?

Nine in the 2023 set (E1-1 to E1-9, plus three ESRS 2-related disclosures: GOV-3, SBM-3 and IRO-1) and 11 in the 2026 set (E1-1 to E1-11).

Which disclosure requirement covers gross GHG emissions?

E1-6 in the 2023 set and E1-8 in the 2026 set, which no longer includes total GHG emissions or GHG intensity as datapoints.

Do companies have to adopt a transition plan?

No: E1-1 is a disclosure duty, and an undertaking without a transition plan for climate change mitigation discloses that fact and whether and, if so, when it expects to adopt one (2023 set para 17; 2026 set para 13). The content of a plan is set out under climate transition plans under E1-1.