ESRS E1 Climate Change: The 11 New Disclosure Requirements for 2026

ESRS E1 is the climate standard for European sustainability reporting—and the standard that has undergone the most visible changes in the 2026 revision. The number of disclosure requirements has increased from nine to eleven, the numbering has been shifted throughout starting with the second disclosure requirement, and an option will now be available regarding the reporting threshold for greenhouse gas emissions. This article compares each disclosure requirement before and after the revision and specifies which version applies to which fiscal year.

What is ESRS E1?

ESRS E1 “Climate Change” is the topic-specific reporting standard of the European Sustainability Reporting Standards for all climate-related disclosures. It sets out how companies within the scope of the Corporate Sustainability Reporting Directive (CSRD) must disclose their transition plan, climate risks, Scope 1, 2, and 3 greenhouse gas emissions, energy consumption, and the expected financial impacts of climate change.

ESRS E1 is relevant in practice for two groups: companies that have identified climate change as a material issue based on the dual materiality analysis—which, in practice, is nearly all of them—and those that have not and must therefore explicitly justify this assessment. You can find a breakdown of all twelve standards and how they interact in our overview of all ESRS standards.

What has changed in ESRS E1 between 2023 and 2026?

Two new disclosure requirements have been added; none have been removed. The number of disclosure requirements has increased from nine to eleven. The new entries E1-2 and E1-3 are not new topics, but rather reclassifications: Climate risk identification and resilience analysis were previously covered as separate sections in ESRS E1 and under ESRS 2 IRO-1 and SBM-3, respectively. As a result, starting with the previous disclosure requirement E1-2, each number shifts down by two positions.

This change is the most common source of error when working with the new version. Anyone who has entered “E1-6” as greenhouse gas emissions in internal documents, data catalogs, or software configurations should refer to the targets once the transition takes effect. The following table maps each reporting requirement from the 2023 set to its equivalent in the 2026 version.

The Eleven Disclosure Requirements of ESRS E1 in Detail

The following list reviews each reporting requirement in the 2026 version and specifies, for each one, what has changed compared to 2023. Section references refer to the annex to the delegated act of July 3, 2026.

E1-1: Transition Plan for Climate Protection

The transition plan remains a separate disclosure requirement and is mandatory (paras. 11–13). Companies without a plan must disclose this fact and indicate whether and by when one will be adopted (para. 13). Companies must also disclose whether their greenhouse gas targets are science-based and consistent with the 1.5-degree limit; if this is not the case, they must explain the deviation and provide justification (AR 2a).

What has changed: The number and title remain the same; the level of detail required has been reduced. We cover the structure of such a plan in detail in our Climate Transition Plan (CTP) service.

E1-2: Identification of Climate-Related Risks and Scenario Analysis

New Disclosure Requirement (Paragraphs 14–17). The company must describe how it identifies and assesses financially material physical and transition risks. Scenario analysis is expressly optional in this context: it may be used, for example, if it has already been prepared for other requirements or frameworks (AR 6). If it is used, minimum parameters must be adhered to—at least one high-emission scenario for physical risks and at least one 1.5-degree scenario with no or limited exceedance for transition risks (para. 16).

What has changed: The content was previously scattered across paragraphs 18, 20, and 21, as well as under ESRS 2 IRO-1. What is new is the structure, not the subject matter—and the removal of the requirement for scenario analysis. On the methodological side: Assessment of climate risks.

E1-3: Resilience to Climate Change

New disclosure requirement (paragraphs 18–19). The focus is on the resilience of the strategy and business model to climate-related developments. The content is aligned with ESRS 2 SBM-3.

What has changed: It has been separated from paragraph 19 of the 2023 version. The resilience statement is therefore no longer overshadowed by the risk analysis but must be substantiated independently.

E1-4 and E1-5: Concepts, Measures, and Resources

Both disclosure requirements have largely retained their substance but have been stripped of their structure: they refer to the general disclosure requirements in ESRS 2 (E1-4, para. 20; E1-5, paras. 21–22) for their structure and minimum content. In E1-5, the detailed allocation of capital expenditures and operating expenses to individual measures has been omitted.

Changes: Renumbering of E1-2 and E1-3 to E1-4 and E1-5, title revision for E1-5, and relocation of the structure to the general information section.

E1-6: Climate-Related Goals

Absolute reduction targets for Scope 1, 2, and 3 must be specified, either separately or combined (paras. 23–24). The targets are gross targets: carbon removals, CO2 credits, and avoided emissions may not be included (AR 12). The statement regarding 1.5-degree compatibility remains mandatory (para. 24c).

What has changed: E1-4 has become E1-6, the title has been shortened, and the mandatory tabular breakdown of the target paths has been eliminated.

E1-7: Energy Consumption and Energy Mix

Total energy consumption must be reported in MWh, broken down into fossil, nuclear, and renewable sources (paragraphs 25–28). Companies in sectors with a high climate impact must also provide a breakdown by coal, crude oil, natural gas, and other fossil sources. Self-generated energy must be reported separately. Final energy consumption is the relevant figure (AR 18c).

What has changed: Just the number, from E1-5 to E1-7.

E1-8: Gross GHG Emissions (Scopes 1, 2, and 3)

This is where the most substantial change in the entire standard lies (paragraphs 29–31). The starting point for the reporting boundary remains financial control as defined by the GHG Protocol Corporate Standard (2004). A new provision is the second sentence of AR 19: The company may alternatively use the equity-share approach or the operational control approach. For Scope 3, a screening based on the 15 categories of the GHG Protocol applies; only the significant categories need to be updated annually, while the complete inventory must be updated at least every three years or upon a significant event.

What has changed: E1-6 becomes E1-8, the reference to total emissions is removed from the title, and the accounting boundary becomes an option. To have your methodology reviewed: Carbon Footprint for Companies (CCF).

E1-9: Greenhouse gas removals and mitigation projects financed through CO2 credits

Removals resulting from the entity’s own activities and the value chain, as well as projects financed through certificates, must be presented separately from gross emissions (paragraphs 32–35).

What has changed: Just the number, from E1-7 to E1-9.

E1-10: Internal CO2 Pricing

Disclosures must indicate whether and how internal CO2 prices are factored into decisions—including investment decisions, transfer pricing, or scenario analyses—as well as the average price per metric ton of GHG for each pricing scheme (paragraphs 36–37). Consistency with the prices used in impairment tests is expressly required.

What has changed: The number has changed from E1-8 to E1-10. The consistency with financial reporting is the most interesting aspect: It makes internal CO2 pricing relevant for audits beyond the scope of the sustainability statement.

E1-11: Expected Financial Effects

The expected financial effects of significant physical risks and transition risks, as well as significant climate-related opportunities, must be disclosed (paragraphs 38–42). The disclosures may be based on estimates; a subsequent adjustment is not considered an error.

What has changed: E1-9 has become E1-11. More significant in practical terms than the number itself is the expanded transition relief, which will be discussed in the section after the next.

How do ESRS 1 and ESRS 2 interact with ESRS E1?

The 2026 version moves everything that is not climate-specific into the cross-standard requirements. The Minimum Disclosure Requirements (MDR) are replaced by the General Disclosure Requirements in ESRS 2: GDR-P for concepts, GDR-A for measures, GDR-T for targets, and GDR-M for metrics. ESRS E1-4 and E1-5 refer to these requirements rather than defining their own minimum content.

Two consequences of this are often underestimated in practice. First: The structure of the concept and action plan descriptions is now identical across all topics. Once you set them up correctly for E1, they’re ready to use for E2 through E5, S1 through S4, and G1. Second: The transition provisions are no longer included in the topic standards but are compiled in Chapter 10 of ESRS 1. If you only read E1, you won’t find the deadlines applicable to E1 there.

Which set applies to my company, and when?

The revised version is mandatory for fiscal years beginning on or after January 1, 2027 (Article 3 of the Delegated Act). For fiscal years beginning between January 1 and December 31, 2026, Article 2 grants the option to choose between three alternatives. The selected option must be explicitly stated in the sustainability statement (Article 2, paragraph 2).

Two aspects of the Mixed Approach directly affect ESRS E1 but are rarely mentioned. The exemption regarding the scope of reporting on the value chain explicitly excludes gross emissions under E1-8. And the exemption for joint activities without operational control applies only to the environmental indicators under E2 through E5—E1 is not mentioned. Therefore, those who choose the Mixed Approach do not receive any relief regarding climate metrics. Fundamentals on the scope of application and the reporting process: Reporting under the CSRD.

Which transitional rules from the 2023 set are no longer applicable?

A significant portion of the transitional relief measures from the 2023 package was tied to a threshold of 750 employees. These relief measures no longer apply to entities subject to the CSRD because the CSRD’s application threshold now stands at more than 1,000 employees and more than 450 million euros in net revenue. A company subject to reporting requirements can no longer fall below the 750-employee threshold.

The relevant legislation is Directive (EU) 2026/470 of February 24, 2026, published in the Official Journal on February 26, 2026, and in effect since March 18, 2026. It has also ended the phased implementation: Phases 2 and 3 no longer exist, and publicly traded small and medium-sized enterprises are completely excluded from the scope of application.

Specifically, this concerns the following provisions from Appendix C of ESRS 1 (2023), which can still be found online and in older guidance documents:

• Omission of data points on Scope 3 emissions and total GHG emissions in the first reporting year (Appendix C, paragraph 3, referring to the former E1-6).
• Waiver of all reporting requirements under ESRS E4 for the first two years.
• Exemption from all reporting requirements under ESRS S1 in the first year, and under S2, S3, and S4 in the first two years.

These are replaced by threshold-based transitional provisions in Chapter 10 of ESRS 1 (2026), which apply starting at the new thresholds. For first-wave companies above the thresholds, the following applies: Disclosures regarding expected financial effects in accordance with E1-11 may be omitted entirely for fiscal years prior to 2028, and quantitative disclosures may even be omitted for fiscal years prior to 2030 (ESRS 1, paras. 125(b) and (c)). First-wave companies below the thresholds may omit all disclosure requirements under all topic standards for fiscal years prior to 2027 (para. 126).

Our assessment: No legal text explicitly states that the Section 750 exemptions are inapplicable—this conclusion arises from the interplay between the threshold value and the scope of application. We consider this conclusion to be compelling, but note that it has not yet been reflected in many documents. Anyone who has a project plan from 2024 or 2025 on file should review it in light of this.

Why ESRS-E1 Projects Fail in Practice

The following three points are our consulting assessment based on our projects; they are not requirements of the standard. They describe where, in our view, the transition to the 2026 version will actually entail effort and risk.

First: The new option regarding the reporting threshold is a consistency trap. The freedom to choose between financial control, operational control, and equity share sounds like a relief. It is—as long as you’re only thinking about ESRS E1. Companies that simultaneously report to CDP, have an SBTi target validated, or have a carbon footprint audited according to ISO 14064 have already established a threshold there. If the ESRS threshold differs from this, two emissions figures emerge for the same year—both of which are correct but which any external reader will nevertheless perceive as a contradiction. Our approach: set the boundary once across the entire group, document the decision, and then stop optimizing it separately for each framework. The effort lies in the documentation, not in the calculation.

Second: The three-year cycle for the full Scope 3 inventory shifts the workload rather than reducing it. The fact that only significant categories need to be updated annually noticeably lightens the burden on the reporting cycle. However, this requires a robust assessment of significance across all fifteen categories—and that is precisely where our projects regularly fall short. Anyone who extrapolates Category 1 from accounts payable data and has never thoroughly screened the remaining fourteen cannot justify why any of them should be deemed immaterial. In practice, we recommend deliberately making the first full inventory broader than necessary, because it sets the standard for materiality determinations for the following two years.

Third: The removal of the requirement for scenario analysis merely postpones the discussion; it does not end it. E1-2 continues to require a transparent process for identifying and assessing financially material climate risks. Those who eliminate scenario analysis must demonstrate compliance with this process through other means. In our experience, this is feasible for companies with a small number of well-understood locations; for companies with distributed production or long supply chains, scenario analysis was often the only way to methodically and rigorously substantiate physical risks. Before eliminating it, it is worth asking how the assessment is otherwise to be substantiated—particularly in the event of doubt on the part of the auditor.

Frequently Asked Questions About ESRS E1

Conclusion: First, update the numbering; then, clarify the borderline cases.

The revision of ESRS E1 does not represent a substantive reorientation, but rather a reorganization with two substantive changes: the option regarding the accounting threshold and the three-year cycle for the full Scope 3 inventory. Most of the effort involved in the transition is devoted to something rather unspectacular—ensuring that the new numbering is consistently applied across data catalogs, software configurations, and internal work instructions.

The best next step depends on the fiscal year. Nothing will change for 2025. For 2026, a decision on the reporting option is pending, and it should be made before data collection begins, not after. For 2027, it’s worth clarifying the reporting threshold now—in conjunction with the requirements from CDP, SBTi, and the financial audit, not separately from them.

Sources and Legal Bases

1. European Commission: Delegated Regulation C(2026) 5010 final of July 3, 2026, amending Delegated Regulation (EU) 2023/2772 (Articles 2 and 3, Recital 3). ec.europa.eu (PDF) (as of August 2026).
2. European Commission: Annex to C(2026) 5010 final — ESRS 1 and ESRS E1 (ESRS 1, paras. 122, 125, 126). ec.europa.eu (PDF) (as of August 2026).
3. EFRAG: ESRS E1 Climate Change, version of the delegated act, interactive full text (paras. 11–42, AR 6, AR 12, AR 18, AR 19). knowledgehub.efrag.org (as of August 2026).
4. European Commission: Press release on the adoption of the revised standards, July 3, 2026 (reduction of mandatory data points by over 60%, and of total data points by over 70%). finance.ec.europa.eu (as of August 2026).
5. European Commission: Delegated Regulation (EU) 2023/2772 of July 31, 2023, Annex I (ESRS 1 Annex C, ESRS E1 as amended in 2023). eur-lex.europa.eu (as of August 2026).
6. European Parliament and Council: Directive (EU) 2026/470 of February 24, 2026 (application thresholds, elimination of waves 2 and 3). eur-lex.europa.eu (as of August 2026).
7. EFRAG: [Draft] ESRS E1 Climate Change, November 2025 (technical recommendation to the European Commission). efrag.org (PDF) (as of August 2026).
8. ESMA: Opinion on the revised ESRS, ESMA32-846262651-5440, February 18, 2026. esma.europa.eu (PDF) (as of August 2026).