On 31 July 2025, EFRAG launched for public consultation the revised drafts of the European Sustainability Reporting Standards (ESRS). Among them, ESRS E1 – Climate change has undergone significant modifications aimed at simplifying its application, improving the clarity of metrics, and strengthening the link between climate plans and the objectives of the Paris Agreement.
Although these proposals may still be adjusted before final adoption, they represent an important shift: a more focused standard, with reduced administrative burden but greater requirements in critical areas.
In this Insight we inalyse in detail the key modifications introduced in the July 2025 draft of ESRS E1 – Climate change, comparing how they applied under the 2023 Delegated Act and what changes are now being proposed.
1. Explicit alignment with the 1.5 °C target
2023: the reference to the Paris Agreement was indirect and rather vague. Companies were asked to explain how their transition plans contributed to global climate objectives, but there was no clear requirement to declare compatibility with the 1.5 °C target or to specify what should happen if they were not aligned. Recognised sectoral pathways were not mentioned either.
2025: climate plans must now align with decarbonisation pathways compatible with the 1.5 °C target. If they are not aligned, companies must explain the reasons and implications. The use of recognised sectoral pathways, such as those from the IEA (International Energy Agency) or the SBTi (Science Based Targets initiative) sectoral pathways, is encouraged.
2. Mandatory datapoints: from 64 to 81
2023: ESRS E1 included 64 mandatory datapoints within the standard, applicable only when climate change is assessed as material for the undertaking. In addition, there were other voluntary or complementary datapoints.
2025: The July 2025 draft expands this set to 81 datapoints, providing greater legal and methodological clarity. The materiality principle remains unchanged, meaning that undertakings are only required to disclose these datapoints if climate change is considered material.
3. Transfer of voluntary requirements to the NMIG
2023: voluntary datapoints were integrated into the main body of the standard, mixed with the mandatory ones.
2025: they are removed from the main text and transferred to the NMIG (Non-Mandatory Implementation Guidance). This way, the standard focuses only on mandatory requirements, while voluntary guidance is available separately.
4. Revision of emissions metrics
2023: companies were already required to report scope 1, 2 and 3 emissions, but with less standardised definitions and formats, leaving room for interpretation.
2025: definitions are clarified, formats are standardised, and alignment with international frameworks such as the GHG Protocol is improved, strengthening data comparability and consistency.
5. Greater precision in transition plans
2023: the required content for transition plans was more general, with less detail on milestones and monitoring.
2025: companies must now include interim targets, specify calculation methodologies, and detail how progress will be monitored. The aim is to make transition plans measurable, verifiable, and strategically useful.
6. Resilience and climate risk focus
2023: the analysis of resilience and climate risks was presented in a more generic way.
2025: clearer guidance is provided on applying climate scenarios, identifying physical and transition risks, and linking these analyses with business strategy.
7. Simplified language and lower reporting burden
2023: the text included complex wording and duplications with other standards, which made practical use more difficult.
2025: the language is simplified, redundancies are removed, and the content is reorganised to make it easier for companies to understand and apply.
What does this mean for companies?
- The standard maintains a high level of ambition, but is now clearer, more proportionate, and easier to apply.
- Climate transition plans are no longer just a narrative; they become a strategic and auditable tool.
- Less room for greenwashing: greater clarity and specificity reduce the space to omit relevant information.
- Companies without a climate strategy will have to state this explicitly in their reports, leaving them exposed to scrutiny from investors, media, or regulators.
Consulta pública abierta
The public consultation on the revised ESRS drafts will be open from 31 July to 29 September 2025.
Their content is available for review and feedback from all interested stakeholders.
📄 You can access the drafts here
Do you need support to adapt to the new climate reporting requirements?
At Baisma, we help companies adapt to the evolving reporting landscape under ESRS E1 – Climate change.
From aligning your disclosures with the latest GHG Protocol requirements to prioritising material climate metrics, we provide tailored support to ensure your reporting is rigorous, compliant, and strategically valuable.
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