[EXPLAINED] E1-1: Transition plan
ESRS E1-1: Transition plan for climate change mitigation
1. Introduction
The transition plan is the umbrella disclosure under ESRS E1: it connects your emission-reduction targets, actions, investments, and governance into one strategic narrative. E1-1 is therefore one of the most critical disclosures. I will briefly explain the requirements for companies to disclose their transition plan.
More elaborate articles are available, which can be found below.
2. What is a transition plan?
A transition plan is the roadmap showing how a company will shift from today’s business model to one that works in an economy without adding extra greenhouse gases. It covers:
Targets: measurable GHG reduction commitments (see E1-6).
Actions & levers: concrete decarbonisation strategies such as efficiency, electrification, fuel switching, renewables, or portfolio shifts (see E1-5).
Financial planning: CapEx/OpEx allocated to implement the plan.
Governance: role of board and management in overseeing the plan.
Dependencies: external conditions like new technologies, customer demand, or policy support that the plan relies on.
Progress: reporting on what has been achieved so far.
The ESRSes define a transition plan as follows:
“A specific type of action plan that is adopted by the undertaking in relation to a strategic decision and that addresses:
i. a public policy objective; and/or
ii. an entity-specific action plan organised as a structured set of targets and actions, associated with a key strategic decision, a major change in business model, and/or particularly important actions and allocated resources.”
3. ESRS E1-1 at a glance
E1-1 requires you to disclose:
Read the elaborate breakdown and detailed requirements of ESRS E1-6 here.
![[BREAKDOWN] E1-1: Transition plan for climate change mitigation](https://substackcdn.com/image/fetch/$s_!rTGI!,w_140,h_140,c_fill,f_webp,q_auto:good,fl_progressive:steep,g_auto/https%3A%2F%2Fsubstack-post-media.s3.amazonaws.com%2Fpublic%2Fimages%2F20657086-78d5-4c2d-948b-8af47f39625e_2048x2048.jpeg)
4. How E1-1 links to the rest of ESRS E1
Think of E1-1 as the umbrella:
E1-6 gives the targets,
E1-5 explains the actions, resources and levers,
E1-8 provides the emissions baseline,
E1-11 quantifies the financial effects of risks and opportunities.
Together, these create the evidence base that your transition plan is both strategically credible and financially grounded.
5. Bottom line
E1-1 challenges companies to go beyond ambition and present a credible transformation plan. To comply, you need to:
Show alignment with 1.5°C and EU climate neutrality by 2050.
Connect the dots between targets, actions, financing, and governance.
Be transparent about dependencies, risks of lock-in, and actual progress.
If you do this well, your transition plan becomes a powerful story for investors, regulators, and stakeholders about how your business will thrive in a net-zero economy.
Relevant Standards
ESRS E1
Amended ESRS E1 – Exposure Draft – July 2025