ESRS E1 Overview
ESRS E1 is the climate change standard under CSRD — the most scrutinised of all 12 ESRS standards. It covers governance, strategy, transition planning, targets, and nine specific climate metrics disclosures. Here is everything that falls under E1 and how the pieces fit together.
ESRS E1 is the climate change standard under CSRD — the most scrutinised of all 12 ESRS standards. ESRS E1 contains nine disclosure requirements, each covering a distinct aspect of climate:.
The nine ESRS E1 disclosure requirements
ESRS E1 contains nine disclosure requirements, each covering a distinct aspect of climate:
E1-1 Transition plan: Your strategy for aligning with 1.5°C, with funded milestones and governance.
E1-2 Policies: Climate-related policies — energy efficiency, renewable energy, emissions reduction.
E1-3 Actions and resources: Specific decarbonisation actions and the CapEx/OpEx allocated to them.
E1-4 Targets: GHG reduction targets, renewable energy targets, energy intensity targets.
E1-5 Energy: Total consumption, mix by source, intensity ratio.
E1-6 GHG emissions: Scope 1, 2 (location and market-based), and Scope 3 by category.
E1-7 GHG removals and carbon credits: Separately disclosed removals and offset purchases.
E1-8 Internal carbon pricing: Whether you use an internal carbon price and at what level.
E1-9 Anticipated financial effects: Quantified financial impacts of physical and transition climate risks and opportunities.
How ESRS E1 maps to TCFD
ESRS E1 was designed to be interoperable with the TCFD (Task Force on Climate-related Financial Disclosures) four-pillar framework. Companies that have already prepared TCFD disclosures have a significant head start on ESRS E1.
Governance pillar → ESRS 2 GOV-1, GOV-2 (board and management climate oversight).
Strategy pillar → ESRS E1-1 (transition plan), E1-9 (financial effects), ESRS 2 SBM-3 (material IROs).
Risk management pillar → ESRS E1-2 (policies), E1-3 (actions), ESRS 2 IRO-1 (risk identification process).
Metrics and targets pillar → ESRS E1-4 (targets), E1-5 (energy), E1-6 (GHG emissions), E1-7 (removals).
The key addition in ESRS E1 vs TCFD: double materiality (impact materiality alongside financial materiality) and mandatory XBRL tagging.
Materiality and ESRS E1 — who must report
ESRS E1 applies to all companies where climate change is a material topic following their double materiality assessment. Given the systemic nature of climate risk, very few companies can credibly exclude ESRS E1 entirely.
Companies that may legitimately assess climate as not material: very small companies with no physical assets, no significant energy use, no material Scope 3, and minimal climate risk exposure — typically pure advisory or digital-only businesses in low-emission sectors.
However: ESRS E1-6 GHG emissions disclosure has a specific provision — even companies that assess climate as not material must still disclose gross Scope 1 and 2 GHG emissions in their ESRS 2 general disclosures. There is no full exclusion from climate metrics.
The Amended ESRS (December 2025) reduced the number of mandatory E1 datapoints for Wave 2 companies but preserved the core structure.
Frequently asked questions
Can we exclude ESRS E1 if we assess climate as not material?
Partially. If climate is not material in your double materiality assessment, you can exclude topical E1 disclosures — but you must still disclose gross Scope 1 and 2 GHG emissions under ESRS 2. A full E1 exclusion without any GHG disclosure is not possible.
How long does ESRS E1 reporting take to prepare for the first time?
Typically 6–12 months for the full E1 disclosure set. GHG data collection (E1-6) takes longest — 3–6 months for Scope 3 if supplier engagement is required. The transition plan (E1-1) requires board input and typically 2–3 months of internal development.
Which ESRS E1 datapoints were reduced under the Amended ESRS?
The Amended ESRS (December 2025) reduced mandatory datapoints primarily in E1-9 (financial effects quantification) and removed some granular breakdowns in E1-6. The core structure — E1-1 through E1-9 — remains unchanged. Wave 2 companies should work from the Amended ESRS text.