Disclosure focus
This disclosure asks an organisation to explain the climate-related policies it has in place for both mitigation and adaptation. In practice, that means setting out the main policy commitments, what they cover, and how they guide decisions and behaviour across the business. The focus is not just on whether a policy exists, but on whether it is relevant to the organisation’s actual climate impacts, risks and opportunities.
Practically, the reporting should show the scope and reach of those policies: whether they apply across the whole organisation, specific business units, sites or activities, and how consistently they are implemented. It is useful to be clear about any differences in coverage, for example if some policies apply group-wide while others only cover certain operations or locations.
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 E1-4 sub-elements (LRA working checklist)
State whether the policy covers adaptation.
State whether the policy covers mitigation.
Give the policy’s name.
Set out what the policy is meant to achieve.
Identify who owns or is responsible for the policy.
Link the policy to the climate impacts, risks and opportunities it relates to.
Describe what the policy applies to, and what it leaves out.
How to prepare it
1Start by identifying the policy you are reporting on and record its title, who owns it, and what it is meant to achieve. Make sure the wording you use clearly shows the policy is about climate action, not a different topic.
2Set the boundaries of the policy before drafting the disclosure. State which parts of the business, activities, locations, or time periods are covered, and make the limits explicit so the reader can see what is in and out.
3Check that the policy text or supporting papers show both sides of climate action: how it is intended to reduce or avoid climate harm, and how it is meant to help the business deal with climate-related change. Keep the two areas distinct in your notes.
4Gather the source material that supports each statement you plan to report. Use the approved policy document, internal ownership records, and any related evidence that shows the policy’s purpose, coverage, and link to climate-related impacts, risks, and opportunities.
5Prepare the final disclosure in a way that matches the required items one by one: policy name, objective, mitigation coverage, adaptation coverage, scope and exclusions, related climate impacts, risks and opportunities, and policy owner. If a point is not fully covered, say so plainly rather than filling gaps.
6Before submission, compare your draft against the official source to confirm nothing has been missed, added, or described too loosely. Note any exclusions, changes in wording, or judgement calls so the final record is traceable and easy to review.
Request the data
Request the climate policy details from the policy owner
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What climate-related policy do we have in place, what does it cover, and who owns it?
Use your organisation’s own policy names, team names and risk language first, then map them to the reporting fields. Keep the request in the words people actually use internally, rather than asking in framework terms. Check the source documents and confirm the final wording before sign-off.
Weak request
Please provide the ESRS E1-4 policy information, including the mitigation and adaptation policy, scope, exclusions, related impacts, risks and opportunities, and policy owner.
Why it fails: This uses framework language that many internal owners will not recognise, so it is harder to answer quickly and may lead to incomplete or misread responses. It also does not point the owner to the document, system, version, or boundary they should use.
Better request
Please send the current climate policy document or register entry and confirm: the policy name, its purpose, what business activities it covers, what it leaves out, which climate risks or opportunities it relates to, and who is responsible for it. Include the version/date and where the document is stored.
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
Describe how the organisation defined each policy, what it treated as covered or excluded, and how it linked the policy to climate-related risks, opportunities, and impacts.
Context note
Explain what the policy set is meant to achieve in practice, including how it supports emissions reduction, resilience planning, and the organisation’s response to climate-related issues.
Fluctuation statement
If the policy set changed during the period, note whether that was due to a revised scope, a different owner, or a change in the climate issues the policies are meant to address.
Content index entry
E1-4 Policies related to climate change mitigation and adaptation — [location / page] / [notes]
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner contact
Teams often ask a policy lead or sustainability contact when the real source sits with the business function that actually owns the climate policy.
Framework words, not business terms
Data requests go out using disclosure labels instead of the organisation’s own policy names and team language, so people cannot match the ask to their records.
No clear boundary
Collectors fail to define which entities, sites, or activities sit inside the policy set, so some in-scope items are missed and some out-of-scope items are pulled in.
Wrong time basis
Information is gathered for the wrong reporting period or cut-off date, which leaves the policy set out of step with the period being reported.
Mixed counting basis
One request combines different ways of counting coverage or exclusions, so the resulting dataset cannot be compared on a like-for-like basis.
Source labels stripped out
The original document titles, version names, or file references are lost during collection, making it hard to trace each field back to the source.
Separate populations merged
Policies for mitigation and policies for adaptation are blended into one pool even though they need to be tracked separately for the disclosure.
Missing evidence trail
The team captures the data points but not the supporting metadata, such as source date, owner, or version, so the evidence pack is incomplete.
No sign-off record
Collected fields are passed on without a clear review and approval trail, so nobody can show who checked the data before it moved forward.
Where judgement is often needed
Acquisitions and disposals during the year
Decide whether the policy description reflects the group as it stood at year-end or the business mix during the reporting period, and explain any additions or removals from bought or sold operations.
Different country labels for the same climate topic
Where local wording differs across jurisdictions, use one internal label for the policy and explain how it maps to the various country-level terms used in the business.
Units that sit partly inside the policy boundary
For activities, sites or teams that are only partly covered, state the rule used to include or exclude them and describe any material exceptions.
Choosing the basis for the policy scope statement
If the scope is set by legal entity, operating segment, geography or another internal cut, name that basis clearly and keep it consistent with the rest of the climate narrative.
Using current-year facts versus forward-looking plans
Separate what is already in place from what is planned, and make clear whether the policy text describes implemented controls, future actions, or both.
Measured information versus management estimate
When exact records are not available, say which parts rely on estimates, the method used to build them, and whether the same approach is used across the covered business.
Rounding and small differences in totals
If figures or counts are rounded, note the rounding basis and accept that minor differences may appear between the policy summary and supporting schedules.
Protecting personal or commercially sensitive detail
Aggregate the description where needed to avoid identifying individuals or sensitive sites, and explain the level at which the policy coverage is reported.
Policy owner where responsibility is shared
If ownership sits with more than one function, identify the lead role and briefly explain how oversight is split between the relevant teams or committees.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
Our group has a climate policy called the Climate Transition and Resilience Policy, approved by the board and owned by the chief sustainability officer. It is designed to cut emissions across operations and the value chain, while also strengthening resilience to physical climate stress; it applies to our own sites, logistics, purchased energy, and key suppliers, but excludes activities we do not control and assets held for sale. - The policy is linked to our main climate exposures: energy-price and carbon-cost pressure, process-efficiency opportunities, supply-chain disruption, and flood and heat risks at selected facilities. - It covers both emissions reduction and adaptation planning, with 84% of our operating sites and 79% of our priority suppliers within scope; the excluded 16% of sites are leased premises where we lack operational control, and the excluded 21% of suppliers are low-spend, non-critical vendors.
Synthetic example for practitioner training only. Figures are illustrative and internally consistent.
Illustrative (synthetic) example — Retail and distribution
We operate under a Climate Action and Business Continuity Policy, which the board oversees and the finance director owns day to day. Its purpose is to reduce our footprint and prepare the business for climate-related disruption; it applies to stores, warehouses, transport, and selected product categories, while excluding franchised outlets and third-party brands where we have no direct control. - The policy addresses both lower-emission operations and adaptation measures, and it is tied to our main climate matters: refrigeration and energy-use efficiency, weather-related supply interruptions, and the chance to improve route planning and stock resilience. - In coverage terms, 92% of our owned and operated locations and 68% of our transport spend are included; the remaining 8% of locations are franchised sites, and the excluded 32% of transport spend relates to outsourced carriers outside the policy boundary.
Synthetic example for practitioner training only. Figures are illustrative and internally consistent.
How companies report E1-4 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Italgas S.p.A.
Gas Utilities · Italy · 2025
Italgas S.p.A.'s 2025 Integrated Annual Report includes a Climate Change Policy that outlines the Group’s strategic response to climate change, as noted on page 131. The report also references climate change mitigation activities and a Climate Change Transition plan related to sustainability performance (pp. 118, 128). However, no further detailed narrative items or specific disclosures beyond these mentions were found in the report.
Iberdrola, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Iberdrola’s 2025 Sustainability Report provides some context on policies related to climate change mitigation and adaptation, noting that the company has policies in place to manage these impacts (p.42). However, the disclosure is unclear and does not present a detailed or explicit description of these policies. There is no quotable evidence found in the report regarding specific targets or comprehensive policy details for climate change mitigation and adaptation.
Raben Group
Ground Transportation — Trucking · Netherlands / Poland · 2025
Raben Group’s 2025 Sustainability Report partially addresses climate-related disclosures by outlining the scope of its policies and documents related to environmental, social, and governance matters, including climate-related strategies (p.21). The report mentions integrating climate-related physical risks into risk management processes, though this is not clearly disclosed (p.35). However, no clear headline values or comprehensive narrative on specific climate-related disclosures were found, and several expected datapoints are missing or unclear throughout the report.
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Scenarios to work through
A group policy on climate matters has been drafted for a manufacturer with two business lines: one is covered by emissions-cutting actions, while the other only has weather-resilience measures. The draft also leaves out a small overseas warehouse network because the team thinks it is immaterial.
QHow should you decide whether the policy description is complete enough for this disclosure?
Reveal model answer →Hide answer ↑Check that the write-up names the policy, explains what it is meant to achieve, and makes clear which parts of the business it covers for emissions reduction and which parts it covers for resilience to climate-related conditions. If any part of the business is left out, state that clearly and explain the boundary rather than implying full coverage. The description should also link the policy to the climate effects, risks and opportunities it is meant to address, and identify who owns it internally.
Why this matters · Describe the policy in a way that shows its purpose, coverage, exclusions and internal ownership, rather than leaving readers to infer them.
A preparer finds two climate documents: one board-approved policy on reducing emissions across operations and supply chain, and a separate adaptation note used by facilities teams for flood planning. The team wonders whether to merge them into one narrative or present them separately.
QWhat is the best way to handle the policy naming and explanation?
Reveal model answer →Hide answer ↑Use the names the organisation actually uses, and explain each policy in plain language so a reader can tell which one is about cutting emissions and which one is about preparing for climate-related disruption. If the organisation treats them as one combined policy, describe that combined policy and show both purposes. If they are separate, keep them distinct and avoid blending their scope or objectives.
Why this matters · Name the policy or policies as the organisation uses them, then explain each one clearly enough that mitigation and adaptation are not confused.
A sustainability team has a climate policy that mentions lower energy use, supplier engagement and site flood protection, but the draft disclosure does not say which climate impacts, risks or opportunities the policy is meant to manage. The policy owner is the head of sustainability, while implementation sits with operations and procurement.
QWhat should be added so the disclosure gives a complete picture?
Reveal model answer →Hide answer ↑Add a plain explanation of the climate-related issues the policy is designed to address, such as emissions reduction, physical disruption, transition pressures or related opportunities, as relevant to the organisation. Also identify the person or function that owns the policy, even if day-to-day delivery sits elsewhere. That way the reader can see both the policy’s purpose and who is accountable for it.
Why this matters · Link the policy to the climate matters it is intended to address and make clear who owns it.
A company has a climate policy that applies to all sites, but one acquired subsidiary is still being brought into the group framework. The draft says the policy covers the whole group, without mentioning the subsidiary or the temporary exception.
QHow should the scope statement be handled in this situation?
Reveal model answer →Hide answer ↑Do not present the coverage as broader than it really is. State the normal scope of the policy, then explain any current exclusions or temporary gaps, including the acquired subsidiary if it is not yet covered. The aim is to show the actual boundary of the policy as it stands at the reporting date, not the intended future state.
Why this matters · Be precise about the current boundary of the policy, including any exclusions or transitional gaps.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Transition plan for climate change mitigation → Guide ✓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 ✓Actions and resources in relation to climate change mitigation and adaptation → Guide ✓Show all 10 related disclosures →
FAQ
Questions this page answers
For E1-4, what should I gather before I start drafting the policy disclosure?+−
Start with the page’s listed datapoints: policy title, policy purpose, mitigation coverage, adaptation coverage, policy boundaries, climate links and policy owner. The page also gives a step-by-step preparation flow, so you can use that to turn those inputs into a first draft.
How do I use the E1-4 step-by-step preparation section in practice?+−
Use it as a working checklist to move from source material to a draft disclosure, rather than as a final answer key. It is designed to help you organise the policy information, check what is in scope and identify what still needs evidence.
What does the E1-4 page mean by policy boundaries, and how should I set them for the draft?+−
The page tells you to prepare policy boundaries, so you should define the limits of what the policy covers before drafting. Use the page’s preparation section to make sure the boundary is stated clearly and consistently with the rest of the disclosure.
Who should own the E1-4 policy data and sign off the draft?+−
The page asks you to identify a policy owner, so ownership should sit with the person or team responsible for the policy content and evidence. In practice, that owner should be able to confirm the wording, the scope and the supporting documents before the draft is finalised.
What evidence do I need to make an E1-4 disclosure assurance-ready?+−
The page includes an evidence pack for assurance readiness and also lists six assurance claims to verify. Use both together so each claim has a clear risk point and supporting evidence behind it.
How do I use the six assurance claims on the E1-4 page?+−
Treat them as a check against the draft: for each claim, confirm the related risk and the evidence that supports it. That helps you spot weak points early and build a cleaner assurance file.
What are the common mistakes in E1-4 reporting that this page warns about?+−
The page has a section on common reporting gaps and mistakes, so use it as a pre-submission review list. It is there to help you catch missing datapoints, unclear scope or weak evidence before the draft goes out.
How do I use the E1-4 Prep & Assurance workbook?+−
The workbook is meant to help you collect the required inputs, organise the evidence and prepare for assurance in one place. Use it alongside the page’s step-by-step guidance so the draft, the evidence pack and the review trail stay aligned.
What is the printable Library Card for E1-4 used for?+−
The printable Library Card is a quick reference version of the page content. It is useful when you want a short checklist for meetings, data requests or assurance review without reopening the full page.
How can I turn the E1-4 page into a draft disclosure?+−
Use the draft-output section, which includes visualisation ideas, narrative starters and a content-index line. That gives you a practical starting point for shaping the disclosure into a report-ready draft.
Are there example E1-4 disclosures I can use as a model?+−
Yes — the page includes synthetic illustrative examples, including a quantitative table where relevant. They are there to show structure and presentation, so you can adapt the approach to your own data rather than copy the wording.
More questions this page can help with
E1-4 policy title and policy purpose: what should I ask the business for?How do I collect mitigation coverage and adaptation coverage data for E1-4?What should be included in the E1-4 evidence pack for assurance?How do I check whether my E1-4 policy boundaries are too narrow or too broad?Who is the best policy owner for E1-4 climate disclosure data?What are the most common E1-4 reporting gaps to avoid before submission?How do I use the E1-4 narrative starters in a report draft?What does the E1-4 content-index line look like in practice?Can I use the company report examples on the E1-4 page to benchmark my draft?What climate links should I capture for E1-4 policy disclosure?How do I prepare E1-4 for assurance review without overcomplicating the file?What should I do if my E1-4 policy data is incomplete?
How this library is built
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272 practitioner guides
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