Mastering Climate Disclosures Under CSRD: Practical Guidance for ESRS E1 and Transition Plans

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 older, 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?

Let’s dive into the theory first. Climate transition plans, (CTPs for short) are a primary example where reporting obligations can have direct impact on company strategy. As a sustainability manager, you might run into the problem that there’s nothing to report on: your company has not yet defined a plan that details how the company will enhance and deal with the transition to a low carbon economy. In that case, your role is, before reporting, to guide your company toward a well-structured climate transition plan, a blueprint for how to move toward a low-carbon future.

A credible CTP 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 contribute to climate change mitigation, adopt to the physical consequences of climate change and remain competitive and compliant in a low carbon world where carbon costs are rising and sustainability expectations are tightening.

Why Do You Need to have a CTP?

Climate transition planning isn’t just a regulatory formality,  it’s a strategic tool for business resilience. Disclosures are the tip of the iceberg. Even if CSRD obligations shift, the underlying rationale for a strong transition plan remains.

• Strategic clarity and direction
  A transition plan helps your company identify key emissions drivers and realign your business model with long-term sustainability goals. If net-zero is on your horizon, a transition plan is non-negotiable.
  
  
• Investor confidence and access to capital
  Climate disclosure is already influencing capital flow. For example, MSCI’s Implied Temperature Rise Index evaluates companies based on their transition plans and reduction targets. Scores from such indices directly influence investor decisions and fund allocations.

• Risk and opportunity management
  A solid transition plan forces you to evaluate physical and transitional climate risks at the company level — floods, extreme weather, changing regulations — and build strategies to address them. For industries like manufacturing and insurance, this is already mission-critical.

‍Disclosures as Guidance for Creating Your CTP

When building a credible climate transition plan (CTP), companies don’t have to start from scratch. The disclosure requirements related to climate can actually serve as a practical structure, helping organizations think through the right questions and areas to cover. Whether or not you will be reporting under CSRD, these expectations offer a solid blueprint for what a comprehensive plan should address.

Here are the core areas to consider:

• Governance
  How is climate integrated into your leadership structure? Are climate goals tied to executive incentives or performance reviews? A strong transition plan includes accountability,  both short- and long-term.
• Strategy
  This is the heart of your CTP. What is your roadmap toward climate mitigation and adaptation? How resilient is your business model to climate-related disruptions, and have you analysed key risks?
• Policies
  Which policies govern your climate-related decisions and risk management? Clear policies show that your commitments go beyond words, embedded into how you operate.
• Actions
  Policies must be backed by action. What concrete steps are you taking to deliver on your goals? What internal projects, operational changes, or value chain initiatives are already underway?
• Metrics & Targets
  Every credible plan needs numbers. This includes GHG emissions (Scopes 1–3), energy consumption, intensity, and targets. Whether you're reporting yet or not, tracking these is essential.
• Financial Impact
  What will climate-related risks mean for your bottom line? While many companies delay this part, anticipating financial effects helps demonstrate preparedness, and investors are watching.

In short, even if you're not strictly following ESRS, these disclosures offer a logical structure for how to go about your transition plan. They're not just compliance checklists,  they help ensure your plan is grounded, actionable, and future-proof.

How Did Wave 1 Companies Perform?

Even with years of preparation and significant resources, many large firms struggled to fully meet climate transition plan disclosure expectations under ESRS. Why?

Climate transition plans (CTPs) were among the most challenging disclosures according to a recent study by EY. While 78% of companies published some form of CTP, very few ticked all the required boxes. Disclosure rates varied sharply by sector: infrastructure led the way, while services lagged.

What does this tell us? Even with experience, climate transition planning is a complex matter,  hence one of the most valuable indicators of strategy.

Enel Group: Strategy Built from the Ground Up

Enel’s climate transition plan stands out for its structured clarity. The Italian energy giant starts with a strong statement of intent, followed by well-defined decarbonisation levers and time-bound targets, most of which are SBTi-verified. Their transition plan is fully embedded in corporate strategy, with concrete links to financial planning and operational decision-making.

What sets them apart is transparency. They detail their locked-in emissions, disclose timelines for retiring fossil-based plants, and even address the social impact of closures, like transitioning workers from phased-out sites. While the financial figures tied to these actions could be more centrally disclosed, the overall credibility of Enel’s approach is hard to dispute.

Vattenfall: Detailed, but Dense

Vattenfall’s report offers a detailed breakdown of emission sources and related decarbonisation levers. Their use of prioritisation tables -tagging emissions by importance- helps clarify strategic focus. But in some cases, the line between “lever” and “action” blurs. Their CTP would benefit from streamlining, though they succeed in making capex and opex investments traceable and tied to specific activities.

The Swedish energy provider shows that prioritisation, even when overly detailed, offers valuable insight into internal decision-making and makes the report audit-friendly.

AXA: Engagement Is the Core

AXA, one of Europe’s largest insurance firms, takes a fundamentally different route. Their climate strategy relies heavily on influencing others: clients, underwritings, and portfolio companies. This makes sense, most of their emissions are indirect, and their financial exposure depends on transition-readiness across the economy.

AXA doesn’t just track client transition plans, they help shape them. They’ve created CTP templates for clients, backed by educational initiatives, industry engagement strategies and financial support. Their disclosures are cleaner than most, but it’s their proactive role in ecosystem-wide decarbonisation that sets them apart.

BMW vs. Mercedes-Benz: A Tale of Two Targets

Two global automakers. Two very different approaches.

Mercedes-Benz outlines ambitious climate targets, but their reporting stops there. There’s little context on how these targets were developed, how they’ll be met, or how they link to 1.5°C alignment. It reads more like a promise than a plan.

BMW, on the other hand, offers detailed methodology, including assumptions, challenges, and emission scope-specific breakdowns. Their transparency builds confidence, showing they understand not just what to do, but how, and what’s still uncertain.

DSV: Visual Reporting, Done Right

DSV opts for a visual-first strategy, and graphs and charts dominate their CTP disclosures. While not a substitute for technical detail, these visuals offer clarity on emission sources, decarbonisation levers, and locked-in emissions.

Used as a complement -not a replacement- this is a good way to make complex transition strategies accessible to broader stakeholders. But as always, visuals should support -not substitute- substance.

Why Transition Plans Still Matter, Even Post-Omnibus

The Omnibus proposal may delay CSRD obligations for some companies, but ESRS E1 remains unchanged—and critical. As Anna Csonka pointed out during our webinar, “Even if timelines shift, the scrutiny around climate disclosures won’t. Transition plans will remain a marker of credibility, strategy, and maturity.”

They’re also a central focus for investors. MSCI, for example, uses transition plans to build its Implied Temperature Rise index. Weak or missing CTPs can mean higher capital costs and limited access to sustainable financing.

What Makes a Credible CTP?

Your climate transition plan doesn’t have to be perfect. But it must be real. ESRS E1-1 expects companies to disclose:

• GHG reduction targets (E1-4)
  
  
• Decarbonisation levers and key actions (E1-3)
  
  
• Investments and funding supporting those actions
  
  
• Locked-in emissions and plans to address them
  
  
• Governance and board accountability
  
  
• Implementation progress
  
  
• Social and biodiversity impacts of the plan
  
  
• EU Paris-aligned benchmark inclusion (or reasons for exclusion)
  
  

It might seem like a lot, but it’s doable. Most importantly, it’s a blueprint for action.

What’s Next?

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

The conversation is moving quickly. But 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.