Disclosure focus
This disclosure asks an organisation to explain what it is actually doing, and what it is putting behind those actions, to reduce climate impacts and to adapt to climate-related risks. In practice, that means describing the main mitigation and adaptation measures in place, the resources allocated to them, and how these efforts are being managed over time rather than simply stating broad climate ambitions.
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 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 E1-5 sub-elements (LRA working checklist)
State when the plan is due to start and when it is meant to finish.
List the main steps intended to help the business adjust to climate-related risks or changes.
List the main steps intended to cut emissions.
Show what people, money, and other inputs have been set aside for delivery.
Name the main change in operations, technology, energy use, or process that is meant to lower emissions.
Report the emissions cut already delivered from that change.
Report the emissions cut you expect that change to deliver in future.
How to prepare it
1Start by separating the disclosure into two parts: the actions already in place and the actions planned for the future. For each action, decide whether it is about cutting emissions or about adapting to climate impacts, and keep the two streams distinct in your working papers.
2Define the scope of each item before you draft the response. Make clear which business activities, sites, projects or measures are included, and use the same scope consistently when you describe the action, the spend, the timing and any emissions effect.
3Set out what counts as the main measure for each action. For mitigation, identify the specific decarbonisation measure being used; for adaptation, identify the specific resilience measure. If you are reporting a reduction outcome, make sure the method used to attribute that outcome to the measure is clear and internally consistent.
4Collect the supporting records needed to back up the figures and the narrative. For the spend figure, gather the source documents that support the amount reported; for emissions effects, gather the calculation basis and any underlying assumptions; for timing, gather the implementation plan or milestone evidence.
5Assemble the disclosure in a way that links each action to its cost, timing and effect. Report the amount of resources assigned, the period over which implementation is expected, the measure used, and any achieved or anticipated emissions reduction, keeping units and labels consistent throughout.
6Document any exclusions, changes in scope or changes in method, then check the final wording and numbers against the official source before sign-off. Confirm that the narrative matches the evidence, that totals and units are consistent, and that nothing has been added, omitted or reclassified without explanation.
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.
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
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
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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 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 only
People 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 set
The 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 basis
The 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 basis
One source uses committed amounts while another uses spent amounts, and the final pack combines them as if they were the same measure.
Source labels lost
The 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 merged
Mitigation 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 trail
The 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 record
The final dataset is circulated without a named reviewer or approval step, leaving no clear trail of who checked the content before it moved on.
Where judgement is often needed
Set the reporting perimeter after a buy-in or sale
If 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 differ
Where 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 operations
For 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 delivery
If 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 estimates
When 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 totals
If 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 publication
Where 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 teams
If 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 included
If 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
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
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.
Illustrative (synthetic) example — Food retail
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.
How companies report E1-5 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj’s 2025 Annual Report includes some contextual references to greenhouse gas (GHG) emissions, mentioning total emissions figures and reductions in a somewhat unclear manner on page 95, and notes that GHG emissions are included in their calculations with some exclusions in Scope 3 categories on page 97. The report also references climate change mitigation and adaptation efforts across several pages (87, 89, 93), but does not provide clear or detailed quantitative disclosures of emissions values or related monetary impacts. Overall, no definitive or comprehensive data points for emissions or financial impacts were found, and several expected narrative and monetary disclosures are missing or unclear.
Bakkafrost P/F
Food Production — Animal Source · Faroe Islands · 2025
Bakkafrost P/F’s Integrated Annual Report 2025 partially addresses climate-related disclosures, noting on page 59 the use of key accounting estimates and judgements related to greenhouse gas (GHG) emissions from upstream transport of purchased goods. The report also mentions on page 88 that Scope 1 and 2 GHG emissions increased in 2025, and on page 78 it highlights activities related to climate change mitigation through renewable energy generation. However, the report lacks specific headline values or quantifiable emissions data, with no clear disclosure of total emissions or monetary values associated with climate impacts.
Telecom Italia S.p.A.
Telecommunication Services · Italy · 2025
Telecom Italia S.p.A.'s 2025 Annual Report provides a specific monetary value for climate change mitigation operational expenditure, reporting 23.8 thousand euros on page 185. The report also references actions and resources related to climate change policies and adaptation, with mentions on pages 151 and 185 indicating planned financial allocations consistent with the company's transition strategy. However, the report does not include any quantifiable emissions data or further detailed narrative items related to emissions or other climate-related metrics.
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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.
QHow should the preparer separate the climate work into the right parts, and what should be captured for the money and timing fields?
Reveal model answer →Hide answer ↑Split the programme into the two kinds of action: one set for cutting emissions and one set for dealing with climate impacts. Then record the amount of money set aside for the work and describe the expected timing for putting it into effect, using wording that matches the organisation’s own plan rather than a generic label.
Why this matters · Keep mitigation and adaptation actions distinct, and pair them with the resources and delivery timetable that relate to each plan.
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.
QWhat should the preparer do when reporting the action type and the emissions figures for completed versus planned work?
Reveal model answer →Hide answer ↑Describe the decarbonisation measure in plain business terms, then show the emissions reduction already achieved from the completed work and the reduction expected from the approved future work. Do not merge the two figures, because one reflects realised outcomes and the other reflects anticipated impact.
Why this matters · Report actual and expected emissions reductions separately, linked to the relevant decarbonisation measure.
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.
QShould the preparer limit the disclosure to the funded phase, or include the broader adaptation plan with its timing and resources?
Reveal model answer →Hide answer ↑Include the full adaptation response that the organisation has identified, not just the part already funded, and explain the timing for implementation. The resource figure should reflect what has been set aside for the action being described, so the narrative and the amount need to align.
Why this matters · The disclosure should reflect the organisation’s identified adaptation response, together with the resources and timing attached to it.
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.
QHow should the preparer organise the actions so the reader can understand what is being done and why?
Reveal model answer →Hide answer ↑Organise the actions by their main purpose: measures aimed at lowering emissions in one group, and measures aimed at strengthening resilience to climate impacts in another. If an item serves both purposes, explain that clearly in the organisation’s own words so the reader can see how it fits without double counting.
Why this matters · Use a clear split between emissions-cutting work and resilience work, and explain any overlap in a way that avoids confusion.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Transition plan for climate change mitigation →Internal carbon pricing →Anticipated financial effects from material physical and transition risks and potential climate-related opportunities →Identification of climate-related risks and scenario analysis →Resilience in relation to climate change →Policies related to climate change mitigation and adaptation →Show all 10 related disclosures →
FAQ
Questions this page answers
What do I need to gather for E1-5 before I start drafting the disclosure?+−
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.
How do I use the step-by-step 'how to prepare' section for E1-5 in practice?+−
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.
Who should own the E1-5 data collection across sustainability, HR and business teams?+−
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.
What evidence should I keep for E1-5 so the disclosure is assurance-ready?+−
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.
How do I check the six assurance claims for E1-5 before review?+−
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.
What are the common reporting mistakes on E1-5 and how do I avoid them?+−
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.
How do I turn the E1-5 data into a draft disclosure?+−
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.
Can I use the synthetic example disclosure to draft my own E1-5 table?+−
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.
What should I put in the climate spend and delivery timing fields for E1-5?+−
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.
How do I use the Prep & Assurance workbook for E1-5?+−
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.
What is the printable Library Card PDF for E1-5 used for?+−
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
E1-5 climate change disclosure: what datapoints should I collect first?E1-5 how to prepare the disclosure step by stepE1-5 assurance-ready evidence pack what should be includedE1-5 common mistakes in reporting mitigation and adaptation measuresE1-5 how to assign ownership for climate spend and emissions reduction dataE1-5 how to use the workbook to build a draft disclosureE1-5 synthetic example disclosure table how should it lookE1-5 narrative starters for a draft disclosureE1-5 content index line exampleE1-5 what evidence supports delivered emissions cut and expected emissions cutE1-5 how to check claim risk evidence before assuranceE1-5 from company reports examples where the topic is disclosed
How this library is built
312 published reports indexed
63171 pages with page-level citations
247 practitioner guides
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