Disclosure focus
This disclosure asks an organisation to explain whether it has a climate transition plan, and if so, how that plan is set up to move the business towards lower greenhouse gas emissions and climate resilience over time. In practice, the focus is on whether the plan is real, current and connected to the organisation’s strategy, targets and actions — not just a high-level ambition statement.
The reporting should cover the parts of the business that matter to the transition, rather than only a few showcase sites or projects. Practitioners should think about whether the plan applies across operations, value chain activities and relevant geographies, and whether it is supported by clear responsibilities, milestones and implementation steps.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show E1-1 sub-elements (LRA working checklist)
State whether the metric is shown as a total amount or as a measure of output or activity.
Say whether the plan is aligned with the organisation’s climate goal.
Confirm if the board has signed off on the plan.
List the capital spending linked to the plan.
Describe steps to improve energy use.
Describe any move away from one fuel to another.
Identify where the money for the plan will come from.
Set out how the plan is organised and managed.
Include the milestones expected before the final target date.
Explain the approach used to build the plan.
State the organisation’s long-term climate target.
List the operating costs linked to the plan.
Name the groups that oversee delivery.
Set out the investments that are planned.
Describe any changes to products or services.
State any planned use of renewable power or fuel.
Name the scenario used to test the plan.
Set out the targets for direct, purchased and value-chain emissions.
Describe the actions planned across the value chain.
Show any capital spending planned for coal-related activities.
Show any capital spending planned for gas-related activities.
Show any capital spending planned for oil-related activities.
Explain the assumptions made about regulation.
Explain any reliance on specific technologies.
Explain any assumptions about workforce availability or skills.
Identify assets with high emissions.
Estimate the emissions over the asset’s full life.
Explain whether these assets could put the plan at risk.
Describe the actions already carried out.
State the emissions cuts already achieved.
Compare key measures with the plan.
Give the date when the plan is expected to be adopted.
State whether a plan exists.
How to prepare it
1Set the boundary first: decide which emissions targets, transition actions, investment plans, governance arrangements and delivery assumptions belong in the response, and make sure the same scope is used throughout.
2Translate each required item into a working checklist: identify whether you need a yes/no answer, a number, a date or a narrative, and separate the items on target type, timing, financing, oversight, assumptions, risks and progress.
3Gather the source material before drafting: pull together board papers, committee minutes, approved plans, budget records, scenario work, implementation updates and any other internal records that support each point.
4Build the disclosure from the evidence: populate the figures, dates and yes/no fields, then write the narrative sections so they explain the target design, the actions underway, the financing, the governance set-up, the assumptions used and the current status against plan.
5Record anything that is left out or has changed: note the reason for any exclusion, estimate, revision or timing shift, and keep a clear audit trail showing what was adjusted and why.
6Check the draft against the official source and the underlying records: confirm every required item is covered, the scope is consistent, the numbers and dates tie back to evidence, and the wording still matches the source intent without copying it.
Request the data
Request the climate transition plan evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What approved plan, supporting assumptions, delivery actions, and funding evidence show how the organisation intends to cut emissions over time?
Use your organisation’s own labels first, then map them to the climate transition plan items for reporting. For example, if your teams talk about the decarbonisation roadmap, net-zero roadmap, capital plan, or transformation programme, use those terms in the request and only translate them into the reporting categories at the end. Keep the ask in business language, not framework language, and check the source material before sign-off.
Weak request
Please provide the ESRS E1-1 transition plan disclosure inputs, including targets, interim targets, net-zero target, decarbonisation levers, capex, opex, governance, scenario analysis, and alignment evidence.
Why it fails: It uses framework wording that many business owners will not recognise, so the request is harder to action. It also bundles too many concepts without telling the owner which internal documents or systems to pull from, or how to present the evidence in their own language.
Better request
Please send the latest climate transition roadmap / decarbonisation plan pack for [period] covering [boundary]. Include the targets and milestones, the main delivery actions, the funding and investment view, the approval trail, the assumptions and constraints, and any progress tracking. Please add document name, version, owner, date, and source link for each item, and use your team’s own terms first so I can map them for reporting.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
State how the organisation defined each target, including whether it is measured in absolute terms or relative to output, and explain the basis used to group targets, milestones, actions, spending and funding information.
Context note
Explain what the figures show about the organisation’s transition approach, including which emissions areas are covered, how ambitious the time horizon is, what practical measures are expected to deliver the change, and how the plan is expected to be financed.
Fluctuation statement
If any target, spending line or funding source changed materially from the prior period, briefly link the movement to a revised plan, updated assumptions, a different delivery timetable, or a change in board approval status.
Content index entry
E1-1 Transition plan for climate change mitigation — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to the wrong team, so the person who actually tracks the decarbonisation plan, budgets, or board papers is never asked for the source records.
Framework language only
The data call is written in reporting jargon, so operational teams cannot match it to the names they use for targets, projects, approvals, or assumptions.
No boundary set
People pull figures from different parts of the business without first agreeing which entities, sites, or activities belong in the pack.
Wrong time basis
The team mixes current-year updates with older planning dates, so the numbers and dates do not all refer to the same reporting cut-off.
Mixed counting basis
Some inputs are captured as whole amounts while others are captured as ratios or percentages, which makes the final set impossible to compare cleanly.
Source labels lost
Original file names, system tags, or document references are stripped out, so nobody can trace each figure back to the exact source.
Separate groups merged
Planned actions, funding, governance, and delivery progress are rolled into one pool even though they need to stay distinct for review.
Evidence details missing
The pack contains the figures but not the supporting notes on where they came from, when they were extracted, or who checked them.
No approval trail
The draft moves forward without a clear record of who reviewed it, who signed it off, and which version was accepted.
Where judgement is often needed
Setting the organisational perimeter after a buy-in or sale
Use the same business perimeter as the rest of the climate plan, and if a deal changes what sits inside it, explain the cut-off date and which sites, teams or assets moved in or out.
Choosing one basis where local labels differ
Where country teams use different names or classifications for the same activity, map them to one internal grouping for the plan and disclose the mapping rule so readers can see how like-for-like items were combined.
Deciding how to treat near-boundary operations
If an activity is partly inside and partly outside the plan’s reach, state the rule used to include, exclude or split it, and explain any material population left just beyond the edge.
Fixing the date used for the plan snapshot
State the reporting date or period-end used for the plan, and if later events changed the picture, explain whether you used the earlier snapshot or updated figures and why.
Separating measured results from estimates
Show which parts of the plan are based on actual tracked outcomes and which rely on assumptions or forecasts, and describe the method used to fill gaps where direct measurement was not available.
Handling whole-number rounding in targets and funding
If figures are rounded, keep the underlying totals internally consistent, explain the rounding basis, and make sure subtotals still reconcile to the headline numbers.
Aggregating sensitive workforce or supplier information
When detail cannot be shown for privacy or confidentiality reasons, group the data at a higher level, say what was combined, and explain any effect on the reader’s ability to compare items across the plan.
Comparing progress when the plan changed mid-year
If the action list, target path or financing mix was revised during the year, disclose the version used for the reported figures and explain how earlier and later measures were made comparable.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Industrial manufacturing
We have set a climate transition plan that covers our direct emissions, purchased energy, and the wider value chain, with a long-term net-zero aim and interim milestones. The plan uses a mix of absolute cuts and emissions-per-unit targets, and it is backed by efficiency upgrades, fuel changes, more renewable power, product redesign, supplier engagement, and planned capital and operating spend; the board has approved it. - Our targets include scope 1, scope 2, and scope 3, with a 2030 interim checkpoint and a 2050 net-zero goal. - We use both absolute reduction goals and intensity-based goals: direct and purchased-energy emissions are targeted to fall 42% by 2030 from a 2024 base year, while emissions per tonne of output are targeted to fall 30% over the same period. - The main levers are a 15% cut in energy use per unit, replacement of natural gas with electrified heat in two plants, 80% renewable electricity by 2030, lower-carbon product design, and supplier programmes covering logistics and raw materials. - Planned investment is 120 million in total, split between 85 million of capital spend and 35 million of operating spend, funded from internal cash flow and a green loan facility; the board approved the plan in 2025.
Synthetic, illustrative wording only; figures are internally consistent and intended to show how a reporter might describe its transition plan in plain language.
Illustrative (synthetic) example — Food and beverage processing
Our transition plan spans emissions from our own sites, purchased electricity, and the rest of the chain, with a net-zero destination and staged checkpoints along the way. We combine absolute and output-based targets, and the delivery package includes efficiency work, switching boiler fuel, buying renewable power, reformulating products, and working with growers and distributors; the board has signed off the plan. - The coverage includes scope 1, scope 2, and scope 3, with a 2028 interim target and a 2040 net-zero target. - We have both absolute and intensity goals: site and purchased-energy emissions are set to fall 35% by 2028 from a 2023 base year, while emissions per unit of product are set to fall 20%. - Delivery actions include a 12% improvement in energy efficiency, moving from gas to biomass in one site, 100% renewable electricity procurement, product reformulation to reduce process emissions, and programmes with farmers and logistics partners. - The plan requires 64 million of investment, made up of 48 million capital expenditure and 16 million operating expenditure, financed through retained earnings and an asset-backed sustainability facility; board approval was obtained in 2024.
Synthetic, illustrative wording only; figures are internally consistent and intended to show how a reporter might describe its transition plan in plain language.
How companies report E1-1 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Mowi ASA
Food Production — Animal Source · Norway · 2024
Mowi ASA's 2024 Integrated Annual Report provides a clear disclosure of its greenhouse gas emission reduction targets, aiming to reduce scope 1 and 2 emissions by 51% (p.72). The report also references a climate transition plan integrated into the overall business strategy and financial planning (p.72), with some supporting context on climate change transition risks related to loans collateralised by immovable property (p.115). However, the report lacks clear numeric disclosures on financial resources allocated to climate action, with only an unclear mention of estimated operational expenditures (p.72), and several expected datapoints are not found or remain unclear throughout the document.
EDP, S.A.
Electric Utilities / IPP / Energy Traders · Portugal · 2025
EDP, S.A.'s 2025 Integrated Annual Report includes a covered narrative on environmental policies such as ISO 14001 certification, a Climate Transition Plan, Nature Management Approach, and Circular Economy Strategy, with specific 2028 targets including 90% renewable generation and Net Zero by 2040 (p.564). The report also references strategic objectives and KPIs related to climate change mitigation and transition plans detailed on pages 58-61 and 65-69. However, no explicit numeric values or detailed methodology disclosures were found, and some narrative elements remain unclear or missing throughout the report.
Bakkafrost P/F
Food Production — Animal Source · Faroe Islands · 2025
Bakkafrost P/F’s Integrated Annual Report 2025 includes a transition plan for climate change mitigation, with specific reference to Scope 1 and 2 emissions, decarbonisation pathways, and abatement levers mentioned on page 86. The report provides supporting context on climate change mitigation, adaptation, energy efficiency, and renewable energy deployment on page 84, but does not present clear headline values or detailed quantitative data. Several expected narrative and numeric disclosures related to this topic are not found or remain unclear throughout the report.
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Scenarios to work through
A group has a climate transition plan that covers only its direct operations. Its finance team also wants to leave out supplier and customer-related actions because those are still being scoped.
QShould the plan be presented as covering only direct emissions, or should it also reflect the wider emissions areas the business has chosen to address?
Reveal model answer →Hide answer ↑The preparer should make sure the plan is framed to match the emissions areas the organisation says it is targeting, rather than limiting the story to direct operations if the wider footprint is part of the plan. If the organisation has set targets or actions across upstream or downstream emissions, those should be reflected in the narrative and evidence set.
Why this matters · The plan should line up with the emissions areas the organisation has actually chosen to manage.
A manufacturer has a long-term climate goal for 2050, but its draft only mentions that end point. It has no nearer milestones, even though management has already approved 2030 and 2040 checkpoints internally.
QCan the disclosure rely on the end-point goal alone, or should it also include the nearer milestones that guide delivery?
Reveal model answer →Hide answer ↑The preparer should include the nearer milestones as well as the long-term goal, because the plan is meant to show the path, not just the destination. If the organisation has set staged targets, those intermediate points belong in the disclosure alongside the final ambition.
Why this matters · A credible transition story shows the steps between today and the long-term target.
A company has drafted a transition plan that depends on cheaper low-carbon technology becoming available and on a new permit regime being introduced. The operations team also says the workforce will need retraining, but that cost and timing are not yet fully settled.
QWhat should the preparer do when the plan depends on outside conditions and internal capability changes that could affect delivery?
Reveal model answer →Hide answer ↑The preparer should spell out the key assumptions and constraints that the plan depends on, including external policy or market conditions, technology availability, and workforce readiness. If those factors could slow or change delivery, they should be described clearly so readers can judge how robust the plan is.
Why this matters · Where delivery depends on assumptions or capability gaps, the disclosure should make those dependencies visible.
A business has approved a climate plan at board level, but the draft report only says “management is responsible” and gives no detail on who oversees progress. The sustainability team also has evidence that some actions have already cut emissions, but the draft does not mention results against the plan.
QShould the disclosure stop at saying the plan exists, or should it also explain who oversees it and what has been achieved so far?
Reveal model answer →Hide answer ↑The preparer should go beyond a bare statement that the plan exists. The disclosure should show how the plan is governed, who keeps an eye on delivery, and what actions have been put in place together with the reductions or progress already achieved against the plan.
Why this matters · Readers need both governance detail and evidence of progress, not just a statement that a plan exists.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Internal carbon pricing → Guide ✓Anticipated financial effects from material physical and transition risks and potential climate-related opportunities → Guide ✓Identification of climate-related risks and scenario analysis → Guide ✓Resilience in relation to climate change → Guide ✓Policies related to climate change mitigation and adaptation → Guide ✓Actions and resources in relation to climate change mitigation and adaptation → Guide ✓Show all 10 related disclosures →
FAQ
Questions this page answers
How do I use the E1-1 climate disclosure page to prepare a draft from the workbook and evidence pack?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints list. Use the workbook to organise the inputs, and keep the evidence pack items together so the draft can be traced back to source material.
What data do I need to collect for E1-1 climate disclosure before I can draft the page?+−
The page lists the datapoints to prepare, including target coverage, target metric type, milestone targets, long-term climate goal, actions, spend, funding sources, governance, scenario assumptions, risks, and progress measures. Use that list as a collection checklist so you can see what is missing before drafting.
How should I set the scope and methodology for the E1-1 climate disclosure?+−
The page points you to scope-related items such as target coverage by scope, assessment method, planning scenario, policy and rule assumptions, technology dependencies, and workforce constraints. Use those inputs to define what the disclosure covers and to explain how the plan was built.
Who should own the E1-1 climate disclosure inputs and sign-off?+−
The page includes board sign-off, governance setup, and oversight groups as datapoints to prepare. In practice, that means you should identify the people who own the underlying data, the governance reviewers, and the person or group that signs off the final draft.
What should go into the evidence pack for E1-1 climate disclosure assurance?+−
The page says there is an evidence pack with five items for assurance readiness, alongside six assurance claims to verify. Use those materials to show the claim, the risk if it is wrong, and the evidence that supports it.
What are the common mistakes to avoid when drafting the E1-1 climate disclosure?+−
The page includes a section on common reporting gaps and mistakes, so it is designed to help you spot missing or weak inputs before you finalise the draft. A practical use is to compare your draft against the datapoints list, the evidence pack, and the assurance claims to check for gaps.
How do I use the E1-1 workbook download to build the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to gather and structure the required inputs, then use the Library Card as a quick reference while drafting and reviewing.
How do I turn E1-1 climate data into a draft narrative and visuals?+−
The page has a draft-output section with visualisation ideas, narrative starters, and a content-index line. That gives you a starting point for turning the collected data into a readable draft rather than a raw data dump.
What should I check in the E1-1 transition plan before I say it is ready for reporting?+−
The datapoints list includes transition plan status, planned adoption date, implemented actions, delivered reductions, and plan versus actual KPIs. Use those to check whether the plan is only planned, partly delivered, or already showing measurable progress.
How do I use the synthetic example disclosures on the E1-1 page without copying them into my report?+−
The page includes synthetic illustrative examples to show how a disclosure might be presented, including a quantitative table. Use them as formatting and completeness references only, and replace every example value with your own internally consistent data.
What does the 'From company reports' table help me do for E1-1 climate disclosure?+−
It links to real published reports at the pages where the topic is disclosed, so you can see how others have presented similar information. Use it as a practical reference point for structure and presentation, not as a template to copy.
More questions this page can help with
E1-1 climate disclosure checklist for target coverage by scope, milestone targets and long-term climate goalE1-1 climate disclosure data collection list for capital spend, operating spend and funding sourcesHow to evidence board sign-off and governance setup for E1-1 climate disclosureE1-1 assurance-ready evidence pack: what documents should I gather?Common mistakes in E1-1 climate disclosure drafting and how to avoid themHow to use the E1-1 Prep & Assurance workbook and printable Library CardE1-1 narrative starters and visualisation ideas for a draft disclosureHow to document planning scenario, assumptions and technology dependencies for E1-1E1-1 transition plan status, planned adoption date and plan versus actual KPIsWhat should be included in E1-1 supply chain measures and workforce constraints?E1-1 synthetic example disclosure table: how to adapt it to my own dataWhere can I find company report examples for E1-1 climate disclosure?
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