Definitions of terms (ESRS)
Definitions of terms (ESRS)
High climate impact sectors
“Sectors that are listed in Sections A to H and Section M (formerly L) of Annex I to Regulation (EC) No 1893/2006 of the European Parliament and of the Council (as defined in Commission Delegated Regulation (EU) 2022/1288 ).”
Source: ESRS Annex II – Acronyms and Glossary (Commission Delegated Regulation (EU) 2026/5010).
NACE
NACE is the statistical classification of economic activities in the European Union (French: “Nomenclature statistique des activités économiques dans la Communauté européenne”). The legal basis is Regulation (EC) No 1893/2006.
New NACE version: NACE Rev. 2.1
New NACE version: NACE Rev. 2.1
The new version NACE Rev. 2.1 has applied since 1 January 2025. The Commission Delegated Regulation (EU) 2023/137 has amended Annex I to Regulation (EC) No 1893/2006 accordingly. The new version has moved the letters of some sections. This change matters for the high climate impact sectors:
Economic sector | NACE Rev. 2 (until 2024) | NACE Rev. 2.1 (from 2025) |
Real estate activities | Section L | Section M (Division 68) |
Financial and insurance activities | Section K | Section L |
Sections A to H keep the same letters. However, their content has partly changed. For example, Section G (trade) in NACE Rev. 2.1 covers only Divisions 46 and 47. The former Division 45 no longer exists.
How do we understand “Section L”?
How do we understand “Section L”?
The ESRS glossary still refers to “Section L”. It refers to Delegated Regulation (EU) 2022/1288. This regulation dates from 2022 and therefore still uses NACE Rev. 2. In NACE Rev. 2, Section L stands for real estate activities.
The Voluntary Standard 2026 (VS 2026, Commission Delegated Regulation (EU) 2026/1560) already uses the new letters for the same term:
„High climate impact sectors are those listed in NACE Sections A to H and Section M as defined in the Annex to Delegated Regulation (EU) 2023/137.“
In plain words: High climate impact sectors are the sectors in NACE Sections A to H and Section M as defined in the Annex to Delegated Regulation (EU) 2023/137.
Our interpretation: High climate impact sectors are Sections A to H and real estate activities. In NACE Rev. 2.1, this is Section M. The financial sector (Section L in NACE Rev. 2.1) is not included.
List of high climate impact sectors (NACE Rev. 2.1)
List of high climate impact sectors (NACE Rev. 2.1)
Section | Division | Description |
A |
| Agriculture, forestry and fishing |
| 01 | Crop and animal production, hunting and related service activities |
| 02 | Forestry and logging |
| 03 | Fishing and aquaculture |
B |
| Mining and quarrying |
| 05 | Mining of coal and lignite |
| 06 | Extraction of crude petroleum and natural gas |
| 07 | Mining of metal ores |
| 08 | Other mining and quarrying |
| 09 | Mining support service activities |
C |
| Manufacturing |
| 10 | Manufacture of food products |
| 11 | Manufacture of beverages |
| 12 | Manufacture of tobacco products |
| 13 | Manufacture of textiles |
| 14 | Manufacture of wearing apparel |
| 15 | Manufacture of leather and related products of other materials |
| 16 | Manufacture of wood and of products of wood and cork, except furniture; manufacture of articles of straw and plaiting materials |
| 17 | Manufacture of paper and paper products |
| 18 | Printing and reproduction of recorded media |
| 19 | Manufacture of coke and refined petroleum products |
| 20 | Manufacture of chemicals and chemical products |
| 21 | Manufacture of basic pharmaceutical products and pharmaceutical preparations |
| 22 | Manufacture of rubber and plastic products |
| 23 | Manufacture of other non-metallic mineral products |
| 24 | Manufacture of basic metals |
| 25 | Manufacture of fabricated metal products, except machinery and equipment |
| 26 | Manufacture of computer, electronic and optical products |
| 27 | Manufacture of electrical equipment |
| 28 | Manufacture of machinery and equipment n.e.c. |
| 29 | Manufacture of motor vehicles, trailers and semi-trailers |
| 30 | Manufacture of other transport equipment |
| 31 | Manufacture of furniture |
| 32 | Other manufacturing |
| 33 | Repair, maintenance and installation of machinery and equipment |
D |
| Electricity, gas, steam and air conditioning supply |
| 35 | Electricity, gas, steam and air conditioning supply |
E |
| Water supply; sewerage, waste management and remediation activities |
| 36 | Water collection, treatment and supply |
| 37 | Sewerage |
| 38 | Waste collection, recovery and disposal activities |
| 39 | Remediation activities and other waste management service activities |
F |
| Construction |
| 41 | Construction of residential and non-residential buildings |
| 42 | Civil engineering |
| 43 | Specialised construction activities |
G |
| Wholesale and retail trade |
| 46 | Wholesale trade |
| 47 | Retail trade |
H |
| Transportation and storage |
| 49 | Land transport and transport via pipelines |
| 50 | Water transport |
| 51 | Air transport |
| 52 | Warehousing, storage and support activities for transportation |
| 53 | Postal and courier activities |
M |
| Real estate activities |
| 68 | Real estate activities |
The NACE classification has four levels:
Section (one letter, for example C)
Division (two digits, for example 20)
Group (three digits, for example 20.2)
Class (four digits, for example 20.20)
You will find the full list with all groups and classes in the Annex to Commission Delegated Regulation (EU) 2023/137.
Tip: Your NACE codes may still date from before 2025, for example from an earlier report or from a register. Check these codes against NACE Rev. 2.1. In the new version, a code may have a different number or belong to a different section.
What does your answer mean?
What does your answer mean?
Yes: Your company operates in a high climate impact sector. Then ESRS E1-7 paragraph 27 applies:
“The undertaking with operations in high climate impact sectors shall further disaggregate its total energy consumption from fossil sources by:
(a) fuel consumption from coal and coal products;
(b) fuel consumption from crude oil and petroleum products;
(c) fuel consumption from natural gas;
(d) fuel consumption from other fossil sources; and
(e) consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources.”
No: This disaggregation does not apply. You disclose total energy consumption under ESRS E1-7 paragraph 26 (fossil, nuclear and renewable sources).
Note: Paragraph 27 does not name a minimum threshold, for example no minimum share of net revenue.
This article has been machine translated. In case of errors, please contact [email protected].