ESRS E1-2 Climate Policies
ESRS E1-2 requires companies to disclose their climate-related policies — the formal commitments governing how they manage climate change mitigation and adaptation. Policies must be more than statements of intent — they must include scope, objectives, and accountability.
ESRS E1-2 requires companies to disclose their climate-related policies — the formal commitments governing how they manage climate change mitigation and adaptation. A climate policy under ESRS E1-2 must describe: the scope of the policy (which operations, geographies, and value chain activities it covers); the key commitments (emission reduction ambitions, renewable energy targets, energy efficiency commitments); the objectives and targets the policy is designed to achieve; and who is responsible for implementation and oversight.
What ESRS E1-2 requires from a climate policy
A climate policy under ESRS E1-2 must describe: the scope of the policy (which operations, geographies, and value chain activities it covers); the key commitments (emission reduction ambitions, renewable energy targets, energy efficiency commitments); the objectives and targets the policy is designed to achieve; and who is responsible for implementation and oversight.
Policies that simply state 'we are committed to reducing our environmental impact' do not satisfy ESRS E1-2. The policy must be specific enough that compliance or non-compliance with it can be assessed.
For companies with multiple policies covering different aspects of climate (energy policy, fleet policy, supply chain carbon policy), you must disclose all material climate-related policies — not just a single overarching document.
Climate adaptation policies
Most companies focus their climate policies on mitigation — reducing emissions. ESRS E1-2 also requires disclosure of climate adaptation policies — how you are preparing your business for the physical climate risks identified in your E1-2/E1-3 risk assessment.
Adaptation policies cover: physical asset resilience (flood protection, heat stress engineering); supply chain diversification away from climate-vulnerable geographies; product adaptation for changing climate conditions; and community adaptation support in areas where you operate.
For many companies, adaptation policy is immature compared to mitigation policy. The Amended ESRS reduced some adaptation disclosure requirements — but a basic adaptation policy statement remains required where physical climate risk is material.
Supply chain and value chain policy scope
ESRS E1-2 policies must address the full scope of your climate impact — including Scope 3 value chain emissions. A climate policy limited to own operations (Scope 1 and 2) does not satisfy ESRS E1-2 where Scope 3 is material.
For supply chain coverage: your procurement policy should include supplier GHG data requirements; your supplier code of conduct should reference climate expectations; and your Scope 3 reduction strategy should be reflected in formal policy commitments.
Investors and assurers will check whether your disclosed policies are consistent with your transition plan and targets. A net zero target without a supply chain policy covering Scope 3 Category 1 is an inconsistency that will attract scrutiny.
Frequently asked questions
Do we need a standalone climate policy document?
Not necessarily — ESRS E1-2 requires disclosure of climate-related policies, not a specific document format. Relevant commitments can be embedded in broader environmental or sustainability policies. What matters is that the required content is present and accessible.
How specific do policy objectives need to be?
Specific enough to be assessable. 'Reduce energy consumption' is not sufficient. 'Reduce absolute Scope 1 and 2 GHG emissions by 50% by 2030 vs 2019 baseline, with annual milestones reviewed by the board' is sufficient.
What if our policy is commercially sensitive?
Climate policies disclosed under ESRS E1-2 are public documents — they must be included in or referenced from your CSRD sustainability report. If specific policy details are commercially sensitive (e.g. supplier pricing commitments), describe the policy approach without the commercially sensitive detail and explain the limitation.