On November 4, 2024, the European Financial Reporting Advisory Group (EFRAG) published the Draft Implementation Guidance on Transition Plans for Mitigating Climate Change. This guidance aims to assist companies in reporting their climate transition plans transparently and consistently under the European Sustainability Reporting Standards (ESRS). Targeted at large companies, the sector-agnostic guidance outlines strategies for emissions reduction aligned with the 1.5°C goal, investment plans, and progress tracking. Public feedback on the draft will be gathered, with the final version expected to be released in early 2025.

Publication Overview and Purpose

On November 4, 2024, EFRAG hosted the first public meeting of its Technical Expert Group (TEG) to discuss the Draft Implementation Guidance on Transition Plans for Mitigating Climate Change (the “Guidance”). This non-binding guidance supports companies in aligning their climate transition plans with the ESRS under the Corporate Sustainability Reporting Directive (CSRD). Its publication marks a significant step toward clearer and standardized climate-related reporting, contributing to the EU’s ambitious climate targets by promoting transparent and consistent practices.

Scope and Sector Focus

The Guidance is intended for large, public and private companies subject to the ESRS but excludes small and medium-sized enterprises (SMEs). Its sector-agnostic approach ensures broad applicability, though specific challenges—such as the unique needs of financial institutions in climate reporting—will be addressed separately.

Based on ESRS E1, the draft focuses on climate change mitigation, requiring companies to disclose operational improvements, product changes, and investments planned to achieve emissions reductions. These disclosures should also include spending aligned with the EU Taxonomy, integration of plans with overall corporate strategy, and governance structures supporting these strategies.

Key Components of the Climate Transition Plan Guidance

The Guidance provides a structured framework to ensure transparent and comparable disclosures. Companies are expected to monitor their progress in implementing these plans, with a flexible approach introduced for the first reporting year to accommodate challenges associated with adopting the new standards.

Frequently Asked Questions (FAQs)

The Guidance includes an FAQ section in Chapter 5, addressing critical topics such as alignment with the 1.5°C target, integrity and accuracy of transition plans, inclusion of subsidiaries, and steps to follow if a transition plan is deemed immaterial. EFRAG plans to issue further clarifications on these FAQs in the coming months.

Supporting Materials: Reference Practices and Workbook

Alongside the Guidance, EFRAG is developing a Reference Practices in Climate Transition Planning document, which will illustrate recommended practices and provide practical examples, such as GHG inventory development and emissions reduction target setting. This document will not be subject to public feedback but will be published separately by the EFRAG Secretariat.

Additionally, EFRAG is preparing an ESRS Workbook, a detailed Excel-based tool mapping all data points required for climate transition plan disclosures under the ESRS. This tool aims to facilitate companies’ understanding of ESRS requirements and compliance obligations.

Alignment with International Standards

Chapter 4 of the Guidance clarifies the interaction of ESRS climate disclosures with other global frameworks, including those from the U.S. Securities and Exchange Commission (SEC), the UK’s Transition Plan Taskforce, and the Glasgow Financial Alliance for Net Zero (GFANZ). While EFRAG acknowledges the usefulness of these frameworks, it emphasizes that adherence to them is not mandatory under ESRS. Nonetheless, EFRAG commits to enhancing coordination with these organizations to foster consistency and reduce reporting burdens for globally operating companies.

Next Steps

EFRAG aims to secure approval of the draft Guidance from the TEG and the Sustainability Reporting Board (SRB) by the end of 2024. Public consultation on the draft is expected to commence in early 2025, with the final version anticipated for publication in spring 2025. This feedback process will enable companies, industry groups, and other stakeholders to share their insights, contributing to the refinement of the Guidance before its broader adoption.

Conclusion

EFRAG’s Draft Implementation Guidance represents a critical milestone in advancing corporate climate reporting within the EU. By creating standardized, sector-agnostic guidance, EFRAG seeks to assist companies in aligning their climate mitigation strategies with ESRS, mitigate greenwashing risks, and promote transparent and actionable climate disclosures.

Currently focused on large companies, the Guidance is expected to evolve with updates and sector-specific supplements. With its commitment to international alignment and continuous improvement, EFRAG’s approach has the potential to become a cornerstone of effective corporate climate reporting in Europe and beyond.