After the EU Omnibus, the Corporate Sustainability Reporting Directive (CSRD) regulations have been notably reduced, including a simplification of the European Sustainability Reporting Standards (ESRS) released on 31st July 2025. This involved the clarification of language and clearer guidance on how to comply as well as changes to what companies are required to report. This article will look at the changes to the ESRS standards impacting ESRS E1 Climate Change.
General Changes
Some changes to the ESRS standards have been implemented across the board and will impact reporting for all subsections. The most significant changes are:
- Sector-specific guidance is no longer going to be developed and any reference to specific sectors within the general guidance has been removed.
- Value chain boundaries have been implemented so companies are only expected to collect data that is seen as reasonable and without undue effort.
- To avoid repetition, there are increased links to other sections of the document.
- Former voluntary requirements have been removed, instead there is a separate Non-Mandatory Implementation Guidance (NMIG), the status of which is still to be evaluated.
Changes to ESRS E1
As well as the overall changes, there have been many changes within the individual standards. Two new sub-categories previously in ESRS 2 General Disclosures were introduced to ESRS E1 (IRO1 Description of the processes to identify and assess material impacts, risks and opportunities and SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business models).
This standard also no longer specifies reporting both climate mitigation and adaptation and has removed or made non-mandatory any financial metrics. The following table outlines the changes made within individual sub-categories.
E1-1: Transition Plan for Climate Change Mitigation
- Clarification that this is a description of the key features. Companies are not expected to publish their transition plan.
- New requirement to show the strategy and business model are compatible with 1.5C warming, previously only for targets.
E1-2: Climate Related Risks and Scenario Analysis – previously IRO 1
- Removed GHG emissions from sub-category as already covered in E1-8 and removed reference to the value chain risks.
- Description of methodology to assess risks, rather than explaining the scenario risks.
E1-3: Resilience in relation to climate change – previously SBM 3
- Category moved to include the extent a company is prepared for climate adaptation in E1, includes impacts on business model and how the reporting organisation would need to respond.
E1-4: Policies Related to Climate change
- Only climate change policies in accordance GDR-P. Removal of policies for identification of risks.
E1-5: Actions and Resources in relation to climate change policies
- Some elements merged to new E1-3.
E1-6: Targets related to climate change
- Removal of information specifying gross targets and that removals/carbon credits are not included within targets.
- Increased flexibility for base and target years.
E1-7: Energy consumption and mix
- Simplification of renewable electricity information to no longer report per source, and purchase and production.
- All companies, not just high climate impact sectors, are now required to disaggregate fossil sources.
E1-8: Gross Scopes 1, 2, 3 and Total GHG emissions
- Reporting boundary specified to financial control boundary in line with reporting undertaking.
- Change of consolidated accounting group and investees reporting separate Scope 1 and 2. Now where financial control reporting is not representative of emissions from operated assets outside of the reporting undertaking, separately report Scope 1 and 2 using an operational control boundary.
E1-9: GHG removals and GHG mitigation projects financed through carbon credits
- More explicit requirement to detail information on GHG removals project.
- Removal of separate disclosure on projects for own operations and value chains.
- Removal of statement that reduction targets are required as this is covered in E1-6.
E1-10: Internal Carbon pricing
- Significant reduction and merging of required detail to singular point regarding information on internal carbon pricing schemes, how applying, consistency of price and price per metric tonne.
E1-11: Anticipated financial effects from material physical and transition risks and potential climate related opportunities
- Material risk points clarified to material risk before adaptation.
- Included a methodology requirement.
- Removal of references to short- medium- and long term.
- Introduced requirement to report estimated potential stranded assets.
- Potential for opportunities moved to NMIG.
How NUS can help
NUS’ Energy and Sustainability Services (ESS) team can support across many aspects of CSRD reporting. This includes Scope 1, 2 and 3 GHG reporting, developing decarbonisation strategies, science-based target setting, energy consumption mix reporting, gap analysis and verification (ISO 14064). For more information contact us online or find your local NUS office.