Disclosure focus
The practical focus is on whether the response is real, targeted and sufficiently broad across the business. Organisations should think about coverage across their own operations and value chain where relevant, not just a few flagship sites or headline projects, and make clear where action is concentrated, where it is still limited, and how resources are prioritised between different climate-related needs.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Mitigation measures
Sustainability / climate strategyDescribe the main steps the organisation is taking to cut or avoid climate harm, focusing on the actions themselves rather than the policy backdrop.
Evidence Climate transition plan, project list, board papers, programme tracker, implementation updates.
Watch for The action list is pulled from a strategy deck and misses the actual project register, so the reported measures do not reconcile to the delivery plan.
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Adaptation measures
Risk / resilienceDescribe the main steps the organisation is taking to prepare for climate impacts and reduce exposure, using the actual measures being put in place.
Evidence Adaptation plan, risk register, resilience programme documents, site-level action plans, management updates.
Watch for The measures are taken from a high-level risk summary and omit site-specific actions, so the reported items miss a sub-population of locations or assets.
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Climate spend
Finance / project controlsCapture the amount of money set aside or used for the reported climate actions, using the same currency basis and period as the underlying budget or project records.
Evidence Budget approvals, project cost tracker, capex/opex reports, finance ledger, forecast files.
Watch for Budget and actual spend are mixed, or the figure does not reconcile to the finance ledger for the reporting period.
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Delivery timing
Programme management / PMOState when the reported actions are due to start, be completed, or reach key milestones, using the organisation’s approved delivery schedule.
Evidence Programme plan, milestone tracker, project timeline, board-approved roadmap, PMO status report.
Watch for The timing is taken from an outdated plan, so the period or milestone dates no longer match the current delivery schedule.
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Emissions reduction method
Operations / engineering / climate strategyName the main operational or technical change that is expected to lower emissions, expressed as the actual lever being used.
Evidence Abatement plan, engineering design, project business case, energy model, decarbonisation roadmap.
Watch for The lever is described at a generic programme level and does not match the specific project mechanism used in the emissions model.
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Delivered emissions cut
Sustainability reporting / carbon accountingCapture the emissions reduction already achieved from the reported action, in tCO2e, using the same boundary and period as the underlying measurement or calculation.
Evidence Verified emissions calculations, monitoring data, project performance report, baseline comparison, assurance file.
Watch for The achieved reduction is calculated on a different boundary or period than the baseline, so the tCO2e figure does not reconcile to the measurement file.
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Expected emissions cut
Sustainability strategy / finance / carbon accountingCapture the emissions reduction the organisation expects from the reported action, in tCO2e, based on the approved forecast or model for the relevant period.
Evidence Forecast model, project business case, scenario analysis, engineering assumptions, approved target tracker.
Watch for The forecast uses assumptions from a different version of the model, so the expected tCO2e reduction does not reconcile to the approved business case.
Before you start
- Have you decided which climate actions belong in this section, and which are outside it?
- For each action, have you fixed the time period and the basis used for the figures?
- Can every amount you plan to show be traced back to a source you can check?
- Have you agreed which internal definition you are using for each action and for the emissions cut it links to?
- Do you know whether you are reporting what has already been delivered, what is planned, or both?
How to prepare it
Request the data
Request climate action plan data from the programme owner
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What climate-related actions, budgets, timings and estimated emissions effects are being tracked for our current mitigation and adaptation work?
Use your organisation’s own programme names, project codes and budget labels first, then map them to the reporting categories. Keep the request in the language the owner already uses for initiatives, spend and delivery milestones, and only translate into the reporting view at the end. This is a possible LRA training template; adapt this to your organisation and check the official source before sign-off.
Weak request
Please provide the ESRS E1-5 actions and resources disclosure inputs, including key mitigation actions, key adaptation actions, resources allocated, implementation timeframe, decarbonisation lever, achieved GHG emission reduction and expected GHG emission reduction.
Why it fails: This uses framework language that many operational owners will not recognise, so it is harder to answer quickly and accurately. It also does not tell the owner which tracker, budget basis, status fields or evidence links to provide, so the response may come back incomplete or inconsistent.
Better request
Please send the current climate programme tracker for [area], showing each initiative’s internal name/code, plain-language summary, funding amount and basis, delivery dates, status, and any emissions-impact estimate you already use. Include the source file or system reference for each line. Use your team’s own labels first, then we will map them to the reporting view. This is a possible LRA training template; adapt this to your organisation and check the official source before sign-off.
Formal email template
Subject: Request for climate action plan details for [reporting period] Hi [name], We are preparing the climate reporting pack and need your help with the current list of mitigation and adaptation initiatives in [business area / programme name]. Please send, for each relevant initiative: - the initiative name or code used internally - a short plain-language description of the work - the amount of funding allocated, with the currency and whether this is approved, committed or spent - the expected delivery window or milestone dates - the current status - the estimated emissions impact, where you track this internally - any evidence links or source files that support the figures Please use your team’s own terminology first, then we will map it to the reporting view. This is a possible LRA training template; adapt this to your organisation and check the official source before sign-off. If it is easier, you can return the information in your usual tracker format and we will convert it. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you share the current [programme / project] tracker for climate mitigation and adaptation in [area]? We need the initiative name/code, short description, funding amount + basis, timing, status, and any emissions-impact estimate you already track. Please use your own labels first; we’ll map them later. This is a possible LRA training template; adapt this to your organisation and check the official source before sign-off. Thanks, [preparer name]
Industry examples
Manufacturing
Context. A plant team is tracking boiler replacement, compressed-air optimisation and flood protection works in separate operational logs.
Adapted request. Please share the site climate tracker for [plant name], including each project’s internal code, short description, approved capex or opex, delivery window, current status, and any estimated energy or emissions benefit already recorded. Include the source document or system link for each item. Use your site’s own project names and budget labels first, then we will map them later. This is a possible LRA training template; adapt this to your organisation and check the official source before sign-off.
Example response. Returned table with project code, site, action summary, funding approved, funding spent to date, start/end dates, status, estimated tCO2e reduction, and links to the capex approval and project tracker.
Financial services
Context. A corporate services team is managing office retrofit, travel reduction and business continuity measures across a property portfolio.
Adapted request. Please provide the portfolio climate actions tracker for [region / portfolio], showing each initiative’s internal reference, plain-language description, budget allocation, delivery timing, status, and any internal estimate of emissions avoided or resilience benefit. Include the budget source and the file or system reference used by your team. Use your own property and programme terms first, then we will map them to the reporting view. This is a possible LRA training template; adapt this to your organisation and check the official source before sign-off.
Example response. Returned spreadsheet with initiative ID, building or portfolio, action summary, budget line, forecast spend, milestone dates, status, estimated emissions reduction, and links to the property plan and finance approval.
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
Explain how the organisation defined each climate action, how it distinguished emissions-cutting measures from resilience measures, and how it measured the resources, timing, and emissions effects reported for each item.
Context note
Set out what the figures show about the organisation’s climate response: which measures are in place, how much support has been committed, when delivery is expected, and how much emissions reduction has already been delivered or is still projected.
Fluctuation statement
If the numbers move materially from one period to the next, link the change to shifts in the action plan, delivery timing, funding levels, or the mix of emissions-reduction measures rather than treating it as a standalone variance.
Content index entry
E1-5 Actions and resources in relation to climate change mitigation and adaptation — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for E1-5 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We prepared the coverage figure from the actions we treated as material for the year, and we documented why each item was included or left out.
Risk Assurer checks whether the population was defined consistently, whether exclusions were selective, and whether the reported figure could be overstated or understated by missing actions.
Evidence to check Scoping memo; inclusion/exclusion criteria; list of candidate actions; management sign-off on the final population; reconciliation between the source list and the published figure.
We split the disclosed actions into separate workstreams so the reader can see which measures sit under each lever, and we kept a mapping from source records to the published categories.
Risk Assurer probes whether the grouping is arbitrary, whether one action has been counted twice, or whether the same activity has been placed in the wrong bucket.
Evidence to check Category mapping file; project register; cross-reference between source records and disclosure table; review notes showing how overlaps and duplicates were resolved.
We used internal records and project trackers to build the numbers, and we checked that the underlying data were complete for the reporting period before we finalised the table.
Risk Assurer checks for missing source data, cut-off errors, inconsistent time periods, and weak control over manual inputs.
Evidence to check Source extracts; data collection templates; period-end cut-off checks; completeness checks; version history; evidence of review by the preparer and reviewer.
We included only the resources we could tie back to approved plans or recorded commitments, and we kept support for the amounts shown in the disclosure.
Risk Assurer probes whether the amounts are supported by real approvals or commitments rather than estimates without basis, and whether the support is traceable to the published figures.
Evidence to check Approved budgets; project approvals; commitment logs; purchase orders or contract summaries where relevant; working papers linking each amount to the disclosure.
We separated current-year spend from amounts expected later, and we used the same basis for each time bucket across the table.
Risk Assurer checks whether the timing split is consistent, whether future amounts are speculative, and whether the same item has been counted in more than one period.
Evidence to check Forecast model; budget timetable; assumptions paper; time-horizon definitions; reconciliation showing no overlap between current and future amounts.
We recorded the non-cash resources using physical or operational measures, and we kept the units and calculation method consistent across the disclosure.
Risk Assurer probes whether the non-monetary quantities are meaningful, comparable, and not mixed with financial amounts or different units without explanation.
Evidence to check Unit definitions; calculation workbook; source operational data; internal review of unit consistency; evidence that the same basis was used throughout.
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe request goes to a central sustainability contact instead of the team that actually runs the project, so the answer is built from second-hand assumptions rather than the operational record.
- Framework language onlyPeople ask for the data using reporting terms instead of the organisation’s own project names, and the business cannot match the request to its live workstreams.
- No boundary setThe team never states which business units, sites, or programmes are in scope, so some actions and budgets are counted while others are left out.
- Wrong period basisThe collection window is not tied to the same reporting period as the source records, so the figures mix current activity with earlier or later updates.
- Mixed counting basisOne source uses committed amounts while another uses spent amounts, and the final pack combines them as if they were the same measure.
- Source labels lostThe original file names, system codes, or project tags are stripped out during consolidation, making it impossible to trace each figure back to its starting record.
- Separate groups mergedMitigation work and adaptation work are rolled into one list even though they are tracked separately in the business, which hides which action belongs to which stream.
- Missing evidence trailThe pack contains the numbers but not the supporting notes, dates, or document references, so reviewers cannot see where each entry came from.
- No sign-off recordThe final dataset is circulated without a named reviewer or approval step, leaving no clear trail of who checked the content before it moved on.
Judgement needed
- Set the reporting perimeter after a buy-in or saleIf a business unit has been added or removed during the period, explain which actions, spend and emissions effects are kept in the current view and which are left out, and state the cut-off date used so readers can see how the change in group structure affects the figures.
- Choose one country basis when local labels differWhere the same activity is described differently across countries or sites, map it to one internal business category, explain the mapping rule, and disclose any material exceptions so the action list stays comparable across the group.
- Decide how to treat near-boundary operationsFor sites, assets or teams that sit close to the reporting boundary, state whether they are included, excluded or only partly counted, and explain the practical rule used to avoid double counting or gaps.
- Fix the timing basis for spend and deliveryIf the organisation tracks budgets, commitments and actual outturns at different points in time, say which date basis is used for each figure and explain any lag between when money is approved and when the action is delivered.
- Separate measured results from modelled estimatesWhen some emissions cuts are directly measured and others are modelled, identify which figures come from actual monitoring and which are estimates, describe the method used for the estimate, and keep the basis consistent across actions.
- Explain how rounding affects the totalsIf individual action figures are rounded, disclose the rounding rule and make clear that small differences may appear between line items and the total, while keeping the published numbers internally consistent.
- Aggregate sensitive site data before publicationWhere site-level detail could reveal commercially sensitive or personal information, combine the data to a higher level, say what has been grouped together, and explain any loss of granularity in the narrative.
- State how shared actions are split across teamsIf one initiative supports both cutting emissions and adapting operations, explain the split method used, show how the same project is not counted twice, and describe the basis for allocating resources and results between the two aims.
- Clarify whether pipeline actions are includedIf the organisation has actions that are approved but not yet started, or started but not yet complete, say whether they are included in the disclosure and explain the rule used to distinguish planned work from live delivery.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We describe a package of near-term climate measures that combines operational cuts with resilience work: we are upgrading process equipment, improving heat recovery, and switching part of our electricity use to lower-carbon supply, while also reinforcing site drainage and cooling systems to cope with hotter summers and heavier rainfall.
- We have set aside €24 million for delivery over 2025–2028; €18 million is for emissions-cutting work and €6 million for climate-resilience measures.
- The main emissions lever is electrification of two production lines, which has already lowered annual emissions by 12,000 tCO2e and is expected to lower them by a further 8,000 tCO2e once the full programme is complete.
- The resilience work includes flood barriers, upgraded stormwater capacity, and additional cooling for critical plant, with the first sites due to finish in 2026 and the full package in 2028.
Synthetic example for practitioner review only; figures and timing are illustrative and internally consistent.
Our climate plan focuses on store operations and supply-chain resilience: we are replacing refrigeration systems, fitting smarter controls, and expanding low-carbon logistics, while also adding backup power and heat-stress measures for stores and distribution sites.
- We have allocated €9 million in total for 2025–2027; €7 million supports emissions reduction and €2 million supports adaptation work.
- The main emissions lever is refrigeration replacement across 40 stores, which has already cut annual emissions by 3,600 tCO2e and is expected to cut a further 2,400 tCO2e when the rollout is finished.
- The resilience package covers backup generators, improved insulation, and staff heat-response procedures, with the first phase due in 2025 and completion planned for 2027.
Synthetic example for practitioner review only; figures and timing are illustrative and internally consistent.
Quality ladder
- Basic
We have set aside €2 million for climate work this year.
- Better
We have allocated €2 million this year to a mix of energy-efficiency upgrades and flood-resilience measures, with €1.2 million for mitigation and €0.8 million for adaptation.
- Best
We have allocated €2 million in 2026 to energy-efficiency upgrades and flood-resilience measures, with €1.2 million for mitigation and €0.8 million for adaptation, and we expect these actions to cut 5,000 tCO2e after the main projects finish because the largest savings come from replacing older equipment and improving site protection.
Check your understanding
Scenarios to work through
A group has one climate programme that includes heat-pump upgrades, staff travel changes, flood barriers at a warehouse, and a budget split across the two workstreams. The project team has draft dates for design, procurement, and rollout, but the board paper is still being refined.
A business has already finished a fleet efficiency project and can show the fuel savings achieved so far. It also has a separate electrification plan that is approved but not yet started, with an estimate of future emissions savings.
A company has a climate adaptation package for a coastal site: drainage upgrades are underway, emergency procedures are being updated, and a second phase is planned for next year. The finance team wants to show only the first phase because the second phase is not yet funded.
A preparer is drafting the note and has a long list of projects: solar panels, building insulation, supplier engagement, flood-proofing, and a resilience review. Some items reduce emissions, some reduce weather risk, and one item supports both. The team is unsure whether to present one combined list or separate the items by purpose.
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Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
E1-5
within ESRS E1: Climate Change
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FAQ
Questions this page answers
Use the page’s datapoint list as your starting checklist: mitigation measures, adaptation measures, climate spend, delivery timing, emissions reduction method, delivered emissions cut and expected emissions cut. The page also gives a step-by-step preparation section to help you turn those inputs into a draft.
Work through the preparation steps in order so you can move from raw inputs to a disclosure draft without missing the key datapoints. The page is designed as a practitioner guide, so it is meant to help you organise the work rather than act as an official source.
The page is set up for practitioners to assign ownership around the datapoints and evidence needed for the disclosure. Use it to decide which team owns each input, then make sure the owner can explain the source and timing of the data.
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those sections to build a file that links each claim to the relevant source documents and supporting records.
The page gives six claim/risk/evidence checks so you can test whether the disclosure is supported and where the weak points are. Use them to spot gaps early and make sure the evidence pack matches what the draft says.
The page lists common reporting gaps and mistakes so you can compare your draft against typical problem areas. Use that list as a final quality check before sign-off, especially where the narrative and the numbers need to line up.
The page’s draft-output section gives visualisation ideas, narrative starters and a content-index line to help you shape the final text. Start with the datapoints, then use the suggested structure to build a clear draft that matches the evidence you have.
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be presented. Treat it as a formatting and drafting aid only, and make sure your own figures stay internally consistent.
The page flags climate spend and delivery timing as datapoints to prepare, so they should be collected and explained as part of the disclosure build. Use the preparation section and evidence pack to make sure those figures are traceable and supported.
The Download Centre includes a Prep & Assurance workbook in .xlsx format to help you organise the disclosure work. Use it alongside the page content to track datapoints, evidence and assurance checks in one place.
The Download Centre also provides a printable Library Card in .pdf format. It is there as a practical companion to the page content, so you can keep the key preparation and assurance points to hand while drafting or reviewing.
More questions this page can help with