ESRS E1-1 transition plan template: the ten things paragraph 16 asks for, the target rules in E1-4, and an Excel workbook that lays them out
A climate transition plan under CSRD is not a narrative document with a net-zero date at the end. ESRS E1-1 lists ten specific things the plan must explain, several of them quantified, and E1-4 sets rules about base years, target values and what counts as science-based. This page is that list, then the target rules, then where a workbook does the arithmetic.
Everything below is from the ESRS text in Commission Delegated Regulation (EU) 2023/2772. Summaries are in Bindler's words; the regulation controls. Not legal advice.
The ten items in E1-1 paragraph 16
| # | What paragraph 16 asks for |
|---|---|
| (a) | How the GHG emission reduction targets (from E1-4) are compatible with limiting warming to 1.5°C in line with the Paris Agreement |
| (b) | The decarbonisation levers identified and the key actions planned, including changes to the product and service portfolio and the adoption of new technologies in own operations, upstream or downstream |
| (c) | An explanation **and quantification** of the investments and funding supporting the plan, referencing the Taxonomy-aligned CapEx KPI and, where relevant, the CapEx plans disclosed under the Taxonomy Delegated Act |
| (d) | A qualitative assessment of **locked-in GHG emissions** from key assets and products: whether they may jeopardise the targets and drive transition risk, and any plans to manage GHG-intensive and energy-intensive assets |
| (e) | For undertakings with activities covered by the climate delegated regulations under the Taxonomy Regulation, an explanation of any objective or plan for aligning them |
| (f) | If applicable, significant CapEx invested in the period in coal, oil and gas-related economic activities |
| (g) | Whether the undertaking is excluded from the EU Paris-aligned Benchmarks |
| (h) | How the transition plan is embedded in and aligned with the overall business strategy and financial planning |
| (i) | Whether the plan is approved by the administrative, management and supervisory bodies |
| (j) | Progress in implementing the plan |
If there is no plan yet, paragraph 17 still requires a disclosure: whether one will be adopted, and if so when.
The target rules that sit underneath it (E1-4 paragraph 34)
The plan's credibility rests on the targets it references, and those have their own rules:
- Absolute first. Reduction targets are disclosed in absolute value, either tonnes of CO2e or a percentage of a base year, and where relevant in intensity value as well. Intensity targets are ratios of emissions to a unit of physical activity or economic output (AR 23).
- Scopes named. Targets are given for Scope 1, 2 and 3, separately or combined; a combined target must say which scopes it covers, the share of each, and which gases. The Scope 2 method used in the target (location-based or market-based) is stated, and any divergence from the E1-6 boundary explained (AR 24).
- Base year discipline. The current base year and baseline value are disclosed; from 2030 the base year is updated every five years. The baseline must be representative, and it is not changed unless the target or the reporting boundary changes significantly. For a new target period, the base year should not precede the first reporting year by more than three years (AR 25).
- 2030, then 2050. Target values must at least include 2030 and, if available, 2050, with values set after every five-year period from 2030.
- The 1.5°C test, stated. The undertaking states whether the targets are science-based and compatible with 1.5°C, how they were derived, whether a sectoral decarbonisation pathway was used, the underlying climate and policy scenarios, and whether the targets were externally assured. For reference, the ESRS application requirements print a cross-sector (absolute contraction) pathway of -42% by 2030 and -90% by 2050 against a 2020 reference year, sourced to the SBTi technical summary (AR 27, AR 28).
- Levers, quantified. The expected decarbonisation levers and their overall quantitative contributions to the targets are described, broken down by scope: energy and material efficiency, consumption reduction, fuel switching, renewable energy, phase-out or substitution of products and processes (paragraph 34(f), AR 30).
- Carbon credits are not a lever. The disclosure has to state whether carbon credits or avoided emissions are counted towards the targets, which is exactly the thing readers check.
What usually goes wrong
Levers that do not add up to the target. If each lever carries a quantitative contribution, the sum has to reconcile to the reduction between baseline and target value. A plan where the levers total 60% of the stated target has a gap that a reader will find. Locked-in emissions treated as an afterthought. Item (d) is about the assets and products already built or sold: their expected future emissions, whether they put the target at risk, and what the plan does about them. CapEx not connected. Item (c) asks for money, tied to the Taxonomy CapEx KPI. A plan with no investment figures answers nine of ten items at best.Where the workbook fits
The ESRS E1 Transition Plan Workbook lays the list out as sheets: a Transition plan sheet with a row per paragraph 16 item and its reference; a Targets sheet on the E1-4 fields (absolute and intensity, scope split, base year and baseline, 2030 and 2050 values, science-based and assurance statements); a Levers and actions sheet where each lever carries its quantitative contribution and the total is reconciled against the target; a Trajectory sheet from baseline to target year with the interim years; a Locked-in emissions sheet for the key assets and products; plus Guide and Sources sheets. $39 single user, team and consultancy licences above.
It pairs with the GHG inventory workbook for the baseline figures, the EU Taxonomy workbook for the CapEx KPI item (c) points at, and the CSRD double materiality workbook for the assessment that makes E1 material in the first place.
Sources
- Commission Delegated Regulation (EU) 2023/2772, Annex I, ESRS E1 Climate change: Disclosure Requirement E1-1 paragraphs 14 to 17; Disclosure Requirement E1-4 paragraphs 30 to 34; Application Requirements AR 23 to AR 30.
- Cross-sector pathway values quoted in the ESRS application requirements, sourced there to SBTi, Pathways to Net-zero, Technical Summary, Version 1.0, October 2021.
Last checked against the source text on 23 September 2026.
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