Climate Disclosure under CSRD: ESRS & Transition Plan Insights

Let’s be honest: CSRD climate disclosures can feel like an administrative maze. But among the noise, one thing remains clear: climate reporting isn’t just a regulatory hurdle. It’s one of the most meaningful, data-driven lenses through which a company can prove it’s not just aware of the transition, but actively shaping it.

In our recent denxpert webinar, our senior sustainability reporting expert, Anna Csonka, unpacked one of the most crucial (but often misunderstood) components of ESRS E1: climate transition plans. While the broader CSRD landscape is shifting due to the Omnibus proposal, climate disclosures remain the most stable piece of the puzzle. Why? Because they build on globally accepted frameworks like TCFD and GRI. Whether or not CSRD timelines shift, investors, stakeholders, and the market aren’t waiting.

So, how are companies responding? Where are they succeeding? Where are they struggling?

What Are the Key Elements of a Climate Transition Plan?

Climate transition plans (CTPs) are a prime example of where reporting obligations directly impact company strategy. As a sustainability manager, you might face the challenge that there’s nothing to report: your company hasn’t yet defined a clear plan to adapt to a low-carbon economy. In that case, your role is to help build one.

A credible climate transition plan isn’t a side project; it should be integrated into the company’s overall strategy. At its core, a transition plan is a clear structure of:

• Defined GHG reduction targets
• Realistic and measurable actions
• Dedicated resources and investments

It should tell the story of how your company plans to mitigate climate change, adapt to physical risks, and remain competitive in a carbon-constrained world where both costs and expectations are rising.

Why Do You Need a Climate Transition Plan?

Transition planning isn’t just a regulatory formality — it’s a strategic tool for business resilience. Even if CSRD obligations shift, the rationale for a strong plan remains:

• Strategic clarity and direction – Identify key emissions drivers and align your business model with long-term sustainability goals.
• Investor confidence – Disclosure scores, such as MSCI’s Implied Temperature Rise Index, influence capital access and investment decisions.
• Risk and opportunity management – Evaluate physical and transitional climate risks (floods, regulation changes, extreme weather) and design strategies to respond.

Disclosures as Guidance for Building Your Plan

Companies don’t have to start from scratch. The climate disclosure requirements in ESRS E1 provide a practical structure for transition plans, helping organizations cover the right questions. Core areas include:

• Governance – Integration into leadership structures and executive accountability.
• Strategy – Roadmap for mitigation, adaptation, and resilience.
• Policies – Formal commitments beyond words.
• Actions – Tangible steps in operations and value chains.
• Metrics & Targets – GHG emissions (Scopes 1–3), energy consumption, reduction targets.
• Financial Impact – Anticipated effects on business performance and investor confidence.

These disclosures are more than compliance checklists — they’re blueprints for a future-proofed climate strategy.

How Did Wave 1 Companies Perform?

Even with years of preparation, many large firms struggled with transition plan disclosures. An EY study found that while 78% of companies published some form of CTP, very few met all requirements. Infrastructure led, services lagged.

This proves how complex (but strategically valuable) CTPs really are.

Company Examples

• Enel Group – Clear targets, transparent timelines for phasing out fossil plants, integration into financial strategy, and attention to social impacts.
• Vattenfall – Detailed emissions analysis with prioritisation tables; thorough but at times dense.
• AXA – Ecosystem approach, supporting client transition plans through templates, engagement, and finance.
• BMW vs. Mercedes-Benz – BMW’s methodology and transparency stand in contrast to Mercedes’s high-level targets without sufficient context.
• DSV – Strong use of visuals to make disclosures accessible, complementing technical data.

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Why Transition Plans Still Matter, Even Post-Omnibus

The Omnibus proposal may delay CSRD timelines, but ESRS E1 climate disclosures remain unchanged. Transition plans continue to be a litmus test of credibility and maturity — for regulators, markets, and investors alike.

As Anna Csonka highlighted: “Even if timelines shift, the scrutiny around climate disclosures won’t. Transition plans will remain a marker of credibility, strategy, and maturity.”

What Makes a Credible Climate Transition Plan?

Your CTP doesn’t have to be perfect, but it must be real. ESRS E1-1 expects disclosures on:

• GHG reduction targets (E1-4)
• Decarbonisation levers and actions (E1-3)
• Investments and funding
• Locked-in emissions
• Governance and accountability
• Implementation progress
• Social and biodiversity impacts
• Paris alignment benchmarks

It’s ambitious, but it’s also a roadmap for actionable strategy.

What’s Next?

In our upcoming denxpert webinar, we’ll unpack the other half of the climate equation: risk assessment and scenario analysis under CSRD. If transition plans are about direction, risk assessment is about preparation.

The conversation is moving quickly. So are the expectations. The time to start is now.

Want help navigating your CTP or CSRD disclosures? Reach out to the denxpert team. We’re here to support your climate journey, whether you’re just starting or already knee-deep in Scope 3.

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