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E1-1 – Transition plan for climate change mitigation

Revised ESRS 2026

ESRS Standard

11. The objective of this DR is to enable an understanding of the undertaking's past, current and future mitigation efforts to ensure that its strategy and business model are compatible with the transition to a sustainable economy and with limiting global warming to 1.5°C in line with the Paris Agreement and the objectives of the European Climate Law (Regulation (EU) 2021/1119), including achieving climate neutrality by 2050.

12. The information about the transition plan for climate change mitigation shall include:

  • (a) a description of its key features. This includes GHG emission reduction targets, the decarbonisation levers, key actions, investments and funding needed to support the implementation of the plan, the approval of the plan by the administrative, management and supervisory bodies, and how the plan is embedded in and aligned with the undertaking's overall business strategy. It shall also include information on how the undertaking's strategy and business model are or will be compatible, pursuant to the implementation of the plan, with the limiting of global warming to 1.5°C in line with the Paris Agreement and with the EU's objective of achieving climate neutrality by 2050;

  • (b) CapEx amounts invested during the reporting period related to coal, oil and gas economic activities if the undertaking has them;

  • (c) information about key assumptions used and dependencies on which the plan relies;

  • (d) a qualitative assessment and explanation of how potential locked-in GHG emissions from key physical assets and products may jeopardise the achievement of the plan and drive transition risk; and

  • (e) an explanation of the undertaking's progress in implementing the transition plan.

13. If the undertaking does not have in place a transition plan for climate change mitigation which includes the key features listed in paragraph 12(a), it shall disclose this fact and indicate whether and, if so, when it expects to adopt one.


Application Requirements (AR)

AR 1 for para. 12 (Transition plan for climate change mitigation)
A transition plan for climate change mitigation sets out how the undertaking intends to transform its strategy and business model to ensure compatibility with the transition to a sustainable economy, and it includes the key features listed out in paragraph 12. The undertaking's transition plan for climate change mitigation can be either stand-alone or included in a broader transition plan covering both mitigation and adaptation aspects. If the undertaking’s transition plan also covers adaptation, the disclosure shall specify this fact and cross-reference the information provided in accordance with ESRS E1-3 and E1-5.

AR 2 for para. 12(a) (Key features description)
In disclosing the key features referred to in paragraph 12(a), the undertaking shall refer, if applicable, to disclosures on policies, actions, resources and targets made elsewhere (e.g. ESRS E1-5 and E1-6 as well as ESRS 2 General Disclosures). The transition plan disclosure consolidates the key features of the undertaking’s plan into a coherent description that demonstrates that they are strategically aligned to drive business transformation. The relevant disclosures under this paragraph are:

  • (a) a statement on whether the GHG emission reduction targets are science-based and compatible with limiting global warming to 1.5°C (with reference to ESRS E1-6, paragraph 24, and the associated Application Requirements (ARs)). If the undertaking discloses information about a transition plan that refers to GHG emission reduction targets that are not compatible with limiting global warming to 1.5°C, it shall explain that in the statement, in particular by explaining how its target value(s) compare with the reference value(s) and how it has considered future developments;

  • (b) decarbonisation levers identified (with reference to ESRS E1-5), including changes in the undertaking’s product and service portfolio and the adoption of new technologies in its own operations, upstream or downstream value chain;

  • (c) the amount of significant financial resources (operational or capital expenditure) allocated or expected to be allocated for the implementation of its transition plan for climate change mitigation, including an indicative range of future financial resources expected (with reference to ESRS E1-5 and ESRS 2 GDR-A). This disclosure can be limited to (a) the approved and announced key actions and action plans and (b) the planned funding sources for implementing those actions (ESRS 2 AR 41).

The disclosure required by paragraph 12(a) focuses on providing the key elements necessary for demonstrating the coherence and credibility of the undertaking’s transition plan for climate change mitigation. The undertaking is not required to disclose detailed internal information used to manage its transition plan for climate change mitigation beyond the scope of this disclosure.

AR 3 for para. 12(c) (Key assumptions and dependencies)
Information on dependencies relate to, for instance, deployment of certain technologies, workforce availability or ability to implement changes in the value chain. If applicable, the undertaking shall include information in line with ESRS 2 GDR-A regarding dependencies on future financial resources and other resources and how these may constrain the actions of the transition plan for climate change mitigation.
Information on assumptions relate to, e.g., expectations about regulatory requirements or the ability of an undertaking to implement planned changes within its value chain.

AR 4 for para. 12(d) (Locked-in emission assessment)
The qualitative assessment of locked-in emissions seeks to ensure that these emissions are adequately considered by the undertaking in its transition plan for climate change mitigation, explaining how the magnitude of the locked-in emissions can potentially put at risk the implementation of the transition plan.

AR 5 for para. 12(e) (Progress explanation)
When explaining its progress in implementing the transition plan for climate change mitigation, the undertaking shall explain quantitative and qualitative components such as the deployment of resources, the actions taken and the GHG emission reductions achieved or expected to be achieved. Information on progress shall include, where applicable, sector-specific metrics that can be used to track progress against specific climate targets that the undertaking may have set, using recognised sectoral decarbonisation standards.


Examples from previous practice

The examples only show how other undertakings have reported a disclosure requirement so far. Audited ESRS reports are not yet available. There is no guarantee that the examples are correct or complete.

E1-1 – Climate change mitigation transition plan

Our transition plan: climate neutrality and the 1.5-degree target

Our transition plan is guided by the aim of limiting global warming to 1.5°C and by the aim of reaching climate neutrality by 2050. These aims are in line with the Paris Agreement and the climate targets of the EU.

Focus on Scope 3 emissions

As a provider of logistics and transport services, about 98% of our emissions are Scope 3 emissions. They arise mainly in the upstream value chain, for example from carriers in shipping, aviation, road and rail transport that provide capacity on behalf of our customers. These emissions are also part of the Scope 3 emissions of our customers.

Decarbonisation levers

Our plan to reduce emissions focuses on minimising the carbon footprint of our customers' supply chains. We use several approaches:

  • Low-emission logistics: selecting partners that actively reduce their emissions, for example through more sustainable modes of transport.

  • Value chain cooperation: working with producers of sustainable fuels such as Sustainable Aviation Fuel (SAF).

  • Science-based targets: setting short-term and long-term emission targets for Scope 1, 2 and 3.

  • Internal emission reduction: measures to reduce the emissions from our own operations.

Science-based targets

Our emission targets are science-based. As early as 2020, we were one of the first logistics service providers in our region to commit to the 1.5°C targets of the Science Based Targets initiative (SBTi). In 2023, our short-term target was validated, and we submitted a long-term target for reaching net-zero emissions under the SBTi Corporate Net-Zero Standard.

Integration into the corporate strategy

Our transition plan is an integral part of our strategy. It is funded through the annual business and financial planning process, which the Management Board and the Supervisory Board approve. Our CFO is responsible for implementing the ESG strategy, including the transition plan. In addition, we include performance indicators for reducing greenhouse gas emissions in our management incentive schemes, to make sure that the targets are implemented effectively.


This article has been machine translated. In case of errors, please contact [email protected].

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