CSRD ESRS E1 (climate) standard: the indicators you must report

Quick answer. ESRS E1 (climate) under EU delegated regulation 2023/2772 requires large companies to report mandatory datapoints: gross GHG emissions (scopes 1, 2 and 3), climate transition plan, reduction targets, energy consumption, carbon removals and internal carbon pricing. These disclosures address double materiality (climate impact + financial risk) and form the core of CSRD climate reporting.

The CSRD directive (Corporate Sustainability Reporting Directive, 2022/2464), transposed into French law by ordinance n° 2023-1142 of December 6, 2023, mandates structured and verifiable sustainability reporting built around the ESRS standards and the climate double materiality assessment. To check whether your company falls within scope, see our article on who is subject to CSRD and its timeline. Climate change is the primary subject of this ESG reporting: investors, banks and clients demand transparency on GHG emissions, energy transition risks and action plans.

ESRS E1 (Environmental standard 1 — Climate change), established in delegated regulation 2023/2772, is the technical instrument that specifies exactly which climate indicators to report and how to calculate them. In effect since January 1, 2024 for the first reporting entities, ESRS E1 is now standard practice for 2025-2026 reporting.

The "Omnibus" package tightened this scope significantly. The substantive directive, approved by the European Parliament in December 2025 and definitively adopted in early 2026 (Directive (EU) 2026/470), raised the main reporting threshold to more than 1,000 employees and more than EUR 450 million in net turnover, cutting the number of directly affected companies by roughly 80%; the former staggered thresholds (500, then 250 employees) no longer apply. In parallel, the "stop-the-clock" directive (EU) 2025/794 postponed the next reporting waves by two years: large companies not yet reporting will cover financial year 2027 (report in 2028), and listed SMEs financial year 2028 (report in 2029). The French transposition of the new threshold is ongoing in 2026. Even outside the mandatory scope, many SMEs report climate data at the request of their customers, lenders or via the voluntary VSME standard.

In 2026, your first or second CSRD report must include E1 datapoints. Non-compliance exposes you to regulatory criticism and loss of investor confidence.

ESRS E1 is a reporting standard that requires disclosure of material climate information from two angles:

1. Impact materiality: how your company impacts climate (GHG emissions produced).
2. Financial materiality: how climate issues impact financial performance (physical and transition risks).

Together, these two angles constitute double materiality: you explain both "I produce emissions" and "I could be harmed by climate change."

ESRS E1 doesn't ask for moral intent, but for precise, verifiable and comparable quantification: emission figures, trajectories, investment plans.

ESRS E1 is structured around nine sections (E1-1 to E1-9), each grouping one or more datapoints. Here are the elements you must report:

E1-1: Climate transition plan#

Requirement: Report if material.

You must describe how your business strategy and operating model integrate climate objectives. Concretely:

• Vision statement for 2030-2050 (trajectory toward net zero, interim reductions).
• Resources allocated (capex, opex budget) to climate transition.
• Governance: who oversees the transition plan at board, committee, management level.
• Current or planned actions (energy efficiency, renewable energy, electrification, technological capabilities).

Format: structured narrative + key figures (budget, timeline).

E1-2 and E1-3: transition policies and actions#

Between the transition plan (E1-1) and the targets (E1-4), the standard sets two intermediate requirements, to be disclosed where material: E1-2 (formalized climate policies: commitments, scope, accountability) and E1-3 (actions and resources deployed: decarbonization projects and associated budgets). For an SME these sections often stay brief; they document the consistency between your stated strategy and the resources actually committed.

E1-4: Climate targets#

Requirement: Mandatory if you have defined GHG targets.

You must publish your climate targets in standardized format:

• Baseline year (e.g., 2020, 2010).
• Target year (e.g., 2030, 2040, 2050).
• Reduction in % or absolute value (e.g., "50% reduction in scope 1+2 emissions by 2030 vs 2020").
• Coverage: what portion of the company and which scopes does the target address?
• Science alignment: is the target aligned with the Paris Agreement (1.5°C or 2°C)? Did you use SBTi (Science Based Targets initiative) methodology?

Standardized table required for each target.

E1-5: Energy consumption#

Requirement: Mandatory.

Report your energy consumption in MWh (or equivalent units) by source and scope:

• Energy consumed (direct = fuel + scope 1 electricity; indirect = scope 2 purchased electricity).
• Breakdown by source: natural gas, coal, grid electricity, renewable energy, other.
• Renewable energy rate: % of consumption covered by renewables (solar, wind, hydro, geothermal).
• Data for 2-3 prior years to show trend.

This allows investors to see whether you're actually reducing consumption or maintaining it.

E1-6: Gross GHG emissions#

Requirement: Mandatory.

This is the core datapoint. You must report:

Scopes 1, 2 and 3 (emissions in tCO₂ equivalent)

Mandatory format:

• Tonnes CO₂ equivalent (scope 1, scope 2, detailed scope 3 if material).
• By calendar year (2024, 2023, 2022 minimum): comparability.
• Intensity: emissions per unit of revenue or headcount (tCO₂/€M or tCO₂/FTE). Enables comparison across different-sized companies.
• Methodology: emission factors used (IPCC, ADEME, GRI, etc.), operational vs financial boundary.
• Scope 3 detailed: if scope 3 is material, list relevant categories (purchased goods, transport and distribution, business travel, employee commutes, waste, other).

Key point: many companies omit scope 3 or calculate it imprecisely. ESRS E1 requires quantification, even if based on prudent estimates.

E1-7: Carbon removals and credits#

Requirement: Mandatory if you use removals or carbon credits.

If you offset part of your emissions through:

• Internal or partner reforestation.
• Voluntary carbon credits purchased (VCS, Gold Standard).
• REDD+ projects, biological absorption, direct air capture.

Report:

• Quantity of removals (tCO₂/year).
• Source (project, location, sector: forests, agriculture, industry).
• Verification methodology.
• Major risk: ESRS E1 demands caution on carbon credits. An absorption based on optimistic assumptions (e.g., reforestation that proves unsustainable) will be questioned by the verifier.

Note: removals do not reduce your gross emissions (E1-6), they are reported for information or voluntary offsetting purposes.

E1-8: Internal carbon pricing#

Requirement: Mandatory if you use internal carbon pricing.

Some large companies apply an internal carbon cost to investment projects to integrate climate risk into financial decisions. Examples:

• Energy audit: added cost = €50/tCO₂/year × expected reductions.
• Heating choice: electric (carbon-free) vs gas (emission factor applied to internal carbon price).

Report:

• Amount of internal price (€/tCO₂) applied.
• Scope: which projects / decisions use it?
• Logic: is this shadow pricing (fictive, for decision-making) or mandatory internal pricing?

This datapoint is less common for SMEs, but relevant if your company steers investments by explicit carbon cost.

E1-9: Physical and transition risks#

Requirement: Mandatory if material.

Report climate risks affecting your company:

Physical risks (climate change impacts):

• Floods, droughts, storms: what impact on your sites, supply chain?
• Rising energy costs.
• Water availability.

Transition risks (regulatory, technological, market changes):

• Future carbon pricing, environmental taxes.
• Bans on polluting technologies.
• Customer demand shifts away from high-carbon products.
• Workforce capability for low-carbon technology operation.

Format: qualitative analysis + financial estimate if possible (e.g., "risk of 15% energy cost increase by 2030").

Large listed companies (>5000 employees)#

Maximum requirement: all E1 sections are material. Scope 3 emissions must be quantified in detail (by category), even if estimated. High expectations on transition plan and SBTi-aligned targets. External verification mandatory.

SMEs / mid-caps (250-5000 employees, applicable from 2028-2029)#

Possible simplification: if your scope 3 is marginal (e.g., online services micro-enterprise), you can claim reduced materiality and limit scope 3 to a prudent estimate. However, E1-6 (gross scopes 1+2 emissions) remains mandatory. Transition plan can be less detailed if your climate risk profile is low.

Climate-exposed sectors (construction, logistics, energy)#

Increased requirement: physical and transition risks are material by default. Climate scenarios (e.g., 2°C vs 3°C impact) must be reported. Highly detailed transition plan required.

• Operational vs financial boundary: decide whether you report on sites you control (operational) or proportional group share (financial, for minority stakes). Keep consistent year-over-year.
• Emission factors: use current factors (ADEME 2024, IPCC 6th Assessment Report). 2020-2021 factors are outdated.
• Scope 3 estimation: if you lack precise data, use estimates (spend-based for purchases, distance-based for travel). Document methodology. Perfect is enemy of good: a prudent estimate beats no scope 3.
• External verifier: ESRS data must be verified by a third party (statutory auditor or accredited auditor). Prepare documentation, retain receipts (energy bills, meter readings, studies).
• Continuous improvement: your 2025 E1-6 becomes baseline for 2026. Any emission increase must be explained (activity growth, boundary change, methodological error?).

Recently, we supported an engineering consultancy (320 employees, CSRD-subject from 2025). Initial scope 3 calculations showed business travel dominated (70% of emissions: flights, trains, car rentals). After analysis, the transition plan included a shift to videoconferencing (target -30% travel by 2030) and purchase of "low-carbon" train tickets for trips <4 hours.

The statutory auditor validated the methodology but demanded stronger evidence: client agreements on travel reduction (dependency), videoconference tool capacity (IT infrastructure), team training. Without this work, figures would have been challenged. The lesson: ESRS E1 isn't just statistical calculation. It's a narrative where quantified datapoints must align with your real, verifiable strategy.

Hayot Expertise advice. Start now with a baseline GHG audit covering all three scopes (2024 or 2025 baseline). This audit serves as year 0 for your 2030 targets. Define targets with rigor (ideally using SBTi methodology or science-based approach). Identify your transition plan: which investments, which partners (energy renovation, renewable energy, low-carbon logistics)? Document emission factors and retain sources. Then report in ESRS E1 format (our RSE and CSRD reporting service guides you from diagnosis to drafting and verification). Before external verification, we conduct a pre-audit to avoid statutory auditor surprises. Consult us now to refine your 2026 roadmap.