ESRS E1-3 Actions & Resources
ESRS E1-3 requires companies to disclose the specific actions taken or planned to address climate risks and opportunities — and the financial resources allocated to those actions. This is where strategy meets reality: funded actions with timelines, not policy statements.
ESRS E1-3 requires companies to disclose the specific actions taken or planned to address climate risks and opportunities — and the financial resources allocated to those actions. ESRS E1-3 requires disclosure of key actions taken or planned to achieve your climate policies and targets.
What constitutes a climate action under ESRS E1-3
ESRS E1-3 requires disclosure of key actions taken or planned to achieve your climate policies and targets. For each significant action, you must disclose: the nature of the action (technology investment, operational change, supply chain engagement, policy advocacy); the expected outcomes in terms of emission reductions or climate resilience improvement; the timeline for implementation; and the financial resources committed.
Actions must be specific and funded — not aspirational. 'Transition to renewable energy' is not an action. 'Install 2MW rooftop solar at our four manufacturing sites by Q4 2027, funded by €3.2M CapEx approved in 2026 budget' is an action.
For companies with large decarbonisation programmes: you do not need to list every individual project. Group actions by theme (energy efficiency, fleet electrification, renewable energy procurement, supply chain engagement) and disclose aggregate resources and expected outcomes by theme.
CapEx and OpEx disclosure — connecting to financial planning
ESRS E1-3 requires disclosure of the CapEx and OpEx allocated to climate actions in the current reporting period and planned for future periods. This connects sustainability reporting directly to financial planning.
CapEx: Capital investment in physical assets that reduce emissions or improve climate resilience — solar panels, EV charging infrastructure, energy-efficient equipment, flood defences, heat pumps.
OpEx: Operating expenditure on climate actions — renewable energy premium costs, carbon offset purchases, sustainability consultant fees, supplier engagement programme costs, climate data platform subscriptions.
The financial figures in E1-3 must be consistent with figures disclosed in your financial statements. Assurers will cross-check climate CapEx against your capital expenditure disclosures. Inconsistencies are a common first-year finding.
Scope 3 actions — the hardest part
Decarbonising your own operations (Scope 1 and 2) is relatively straightforward — you control the assets and can make capital investment decisions. Scope 3 decarbonisation requires influencing behaviour across your supply chain and customer base, which is fundamentally more complex.
For Scope 3 Category 1 (purchased goods): supplier engagement programmes, sustainability criteria in procurement, supplier transition support funds, and co-investment in supplier decarbonisation.
For Scope 3 Category 11 (use of sold products): product redesign for lower in-use emissions, take-back and refurbishment programmes, customer education on low-carbon usage, and electrification of product lines.
ESRS E1-3 requires you to disclose the specific actions you are taking on material Scope 3 categories — not just a general commitment to engage suppliers.
Frequently asked questions
Do we need to disclose the exact budget for each climate action?
ESRS E1-3 requires the financial resources allocated — aggregate figures by action theme are acceptable. Exact project budgets are not required in the sustainability report. However, the figures must be consistent with your financial statements and supportable in assurance.
What if our climate actions are still in planning and not yet funded?
Disclose planned actions separately from committed actions. For planned actions, disclose the expected timeline for funding decision and implementation. Unfunded aspirational actions should not be presented as committed actions — assurers will check whether CapEx is actually in approved budgets.
How does ESRS E1-3 connect to our transition plan (E1-1)?
E1-3 is the operational detail that backs up the strategic transition plan in E1-1. The transition plan sets direction and milestones; E1-3 discloses the specific funded actions that will deliver those milestones. Assurers check that E1-3 actions are sufficient to achieve the E1-4 targets disclosed.