# Climate Transition Plan: [Organisation name] [Plan period]

> A climate change mitigation transition plan: the targets, the
> decarbonisation levers, the capital and operating expenditure behind
> them, governance, locked-in emissions and the way progress is tracked.
> The disclosure structure follows the transition plan disclosure
> requirement (E1-1) of ESRS E1 in Delegated Regulation (EU) 2023/2772
> as amended by Delegated Regulation (EU) 2026/1563 of 3 July 2026
> (applies to financial years beginning on or after 2027-01-01), and
> IFRS S2 paragraph 14 (June 2023). The CSDDD obligation to adopt and
> put into effect a transition plan (Article 22 of Directive (EU)
> 2024/1760) was deleted by Article 4, point (16), of Directive (EU)
> 2026/470 (Omnibus I), while the CSRD disclosure of a plan, where one
> exists, remains: check the consolidated texts. Replace every `[bracketed]` value and every row
> marked *Example*. This is a documentation format, not legal, financial
> or investment advice: check the current official texts and a
> qualified professional.

<!--
Guidance: How to use this template
- Purpose: one plan that the board approves and that the sustainability
  statement, lender reporting and capital budget all reference. A plan
  is credible when targets, levers, money and accountability add up.
- Licence rule: ESRS are EU law and may be reused under the EUR-Lex
  reuse policy; IFRS S2 is copyrighted by the IFRS Foundation and is
  cited by paragraph number only; SBTi and GHG Protocol materials are
  referred to by name. All wording, tables and figures here are original.
- Work in this order: baseline (section 3, from the GHG inventory),
  targets (4), levers (5 and 6), money (7), locked-in emissions (8),
  assumptions (9), people (10), risks (11), monitoring (12), then the
  disclosure mapping (13). Governance (2) is filled first but approved
  last.
- The worked example continues the fictional Quillfen Packaging Group
  used in the GHG Emissions Inventory (`finance/ghg-emissions-inventory`):
  base year 2024 recalculated, Scope 1 and 2 market-based 62,120 tCO2e,
  Scope 3 306,400 tCO2e; FY2026 51,551 and 278,340 tCO2e. All money
  figures and abatement estimates are fictional.
- Related documents: ISSB Sustainability Disclosure
  (`finance/issb-sustainability-disclosure`), Double Materiality
  Assessment (`finance/sustainability-double-materiality-assessment`),
  Capex Request (`finance/capex-request`), Investment Appraisal
  (`finance/investment-appraisal`), Annual Budget
  (`finance/annual-budget`), Risk Appetite Statement
  (`finance/risk-appetite-statement`).
-->

## Document control

<!-- Guidance: Record which framework the plan is written for, who approved it and when it is next reviewed. A plan without a board approval date is a draft. -->

| Field | Value |
|---|---|
| Document ID | [CTP-YYYY] *Example:* CTP-2027 |
| Organisation | [Legal name] *Example:* Quillfen Packaging Group N.V. and subsidiaries |
| Plan horizon | [Near term to YYYY, long term to YYYY] *Example:* Near term to 2030, long term to 2050 |
| Base year | [YYYY] *Example:* 2024 (recalculated, see GHG-2026) |
| Frameworks addressed | [ESRS E1 / IFRS S2 or jurisdictional version / UK SRS S2 / voluntary] |
| Target validation | [SBTi / other / none] *Example:* SBTi submission planned under the Corporate Net-Zero Standard |
| Linked inventory | [Document ID] *Example:* GHG-2026 |
| Version | [0.1] |
| Status | [Draft / In review / Approved by the board] |
| Owner | [@chief-sustainability-officer] |
| Approvers/reviewers | [@ceo], [@cfo], [@board-sustainability-committee] |
| Last updated | YYYY-MM-DD |
| Next full review | [YYYY-MM-DD] *Example:* Annually with the budget, full refresh every 3 years |
| Classification | [Internal / Public summary] |

### Approvals

| Role | Name | Decision | Date |
|---|---|---|---|
| Chief sustainability officer | [@name] | [Prepared] | YYYY-MM-DD |
| Chief financial officer | [@name] | [Capital plan confirmed in budget] | YYYY-MM-DD |
| Chief executive officer | [@name] | [Endorsed] | YYYY-MM-DD |
| Board of directors | [@name] | [Approved] | YYYY-MM-DD |

### Revision history

| Version | Date | Author | Change |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | First draft from the FY2026 inventory |
| 0.2 | YYYY-MM-DD | [@name] | Lever costing and capex aligned with the budget |
| 1.0 | YYYY-MM-DD | [@name] | Board approval |

## Contents

1. [Purpose, basis and ambition](#1-purpose-basis-and-ambition)
2. [Governance and accountability](#2-governance-and-accountability)
3. [Baseline and emissions profile](#3-baseline-and-emissions-profile)
4. [Targets](#4-targets)
5. [Operational levers and pathway, Scope 1 and 2](#5-operational-levers-and-pathway-scope-1-and-2)
6. [Value-chain levers, Scope 3](#6-value-chain-levers-scope-3)
7. [Financial planning](#7-financial-planning)
8. [Locked-in emissions](#8-locked-in-emissions)
9. [Assumptions, dependencies and scenarios](#9-assumptions-dependencies-and-scenarios)
10. [Workforce, suppliers and stakeholders](#10-workforce-suppliers-and-stakeholders)
11. [Risks to delivery and contingency](#11-risks-to-delivery-and-contingency)
12. [Monitoring and reporting cycle](#12-monitoring-and-reporting-cycle)
13. [Disclosure mapping](#13-disclosure-mapping)
14. [Glossary and references](#14-glossary-and-references)

## 1. Purpose, basis and ambition

<!-- Guidance: State why the plan exists, which legal or voluntary frameworks it answers, and the ambition in one sentence. Pitfall: an ambition statement with no date, scope or base year. -->

A transition plan explains how the organisation will change its business model, operations and value chain to reach its climate targets, and what that costs. Disclosure rules ask about a plan; few of them require one. Under ESRS E1 as amended (paragraph 13), an undertaking without a plan that has the key features states that fact and whether and, if so, when it expects to adopt one; IFRS S2 paragraph 14(a)(iv) asks for information about any transition plan the entity has, including key assumptions and dependencies. The CSDDD duty to adopt and implement a plan (former Article 22) was deleted by Omnibus I, Directive (EU) 2026/470 of 24 February 2026, so a plan is now a disclosure and business matter in the EU rather than a due diligence obligation; national law and contracts may still ask for one.

| Question | Answer |
|---|---|
| Why a plan now | [Drivers] *Example:* Expected CSRD scope from FY2027, lender sustainability-linked loan terms, two retail customers requiring supplier targets |
| Jurisdictions in view | [EU / UK / US / other] *Example:* EU (ESRS E1), UK (listing and SECR context for the UK subsidiary), US customer requirements |
| Ambition statement | [One sentence] *Example:* Halve Scope 1 and 2 emissions and cut Scope 3 by 30% by 2030 against 2024, and reach net zero across the value chain by 2050 |
| Compatibility claim | [1.5 degrees compatible / not compatible, with explanation] *Example:* Near-term Scope 1 and 2 target designed to be 1.5 degrees compatible; to be confirmed through external validation |
| Scope of the plan | [Entities, scopes] *Example:* All entities in the GHG-2026 boundary, Scopes 1, 2 and 3 |

Where a target is not compatible with limiting warming to 1.5 degrees, the amended ESRS E1 expects the undertaking to say so and to explain how its target values relate to the reference values: write that explanation here rather than implying alignment.

## 2. Governance and accountability

<!-- Guidance: Name the body that approves the plan, the executive who owns delivery, and how pay and capital decisions are linked. Pitfall: a plan owned by the sustainability team with no line ownership of levers. -->

| Body or role | Responsibility | Frequency | Evidence |
|---|---|---|---|
| Board of directors *(Example)* | Approves the plan and targets; oversees progress | Annually, plus quarterly dashboard | Board minutes |
| Board sustainability committee *(Example)* | Reviews lever progress and deviations | Quarterly | Committee papers |
| Chief executive officer *(Example)* | Accountable for delivery | Ongoing | Executive objectives |
| Chief financial officer *(Example)* | Embeds lever capex in the budget and investment appraisal; owns the carbon price used | Annual budget, monthly reporting | Budget pack |
| Plant managers *(Example)* | Own site levers L2, L4 and L5 | Monthly | Site scorecards |
| Chief procurement officer *(Example)* | Owns Scope 3 levers S3-L1 and S3-L2 | Quarterly | Supplier programme report |
| Remuneration committee *(Example)* | Links variable pay to plan KPIs | Annually | Remuneration report |

Incentives: [describe the link to pay]. *Example:* 15% of the executive annual bonus depends on Scope 1 and 2 market-based emissions against the trajectory in section 5.

Internal carbon price: [EUR per tCO2e and use]. *Example:* A shadow price of EUR 100 per tCO2e is applied in investment appraisal for projects above EUR 1 million; it is a decision tool, not a charge.

## 3. Baseline and emissions profile

<!-- Guidance: Take the baseline from the controlled inventory and do not restate it here. Show where the emissions are, because levers follow the profile. Pitfall: a plan built on an older, unrecalculated base year. -->

| tCO2e | Base year 2024 (recalculated) | FY2026 | Main sources |
|---|---|---|---|
| Scope 1 *(Example)* | 28,900 | 24,911 | Natural gas for boilers and dryers (82% of Scope 1 in FY2026) |
| Scope 2 market-based *(Example)* | 33,220 | 26,640 | Poland grid electricity (78% of Scope 2 market-based) |
| Scope 1 and 2 market-based *(Example)* | 62,120 | 51,551 | |
| Scope 3 *(Example)* | 306,400 | 278,340 | Category 1 purchased board and films (65.5%), category 12 end of life (13.7%) |

Source: GHG Emissions Inventory GHG-2026, sections 6 to 9. Any later recalculation of the base year updates this table and the targets in section 4 together.

## 4. Targets

<!-- Guidance: Give each target a scope, base year, target year, metric and the basis for its level. Absolute targets first, intensity targets as a supplement. Pitfall: a net-zero target with no interim target. -->

| Target ID | Scope | Metric | Base year value | Target year | Target value | Reduction | Basis |
|---|---|---|---|---|---|---|---|
| TGT-01 *(Example)* | Scope 1 and 2 market-based | Absolute tCO2e | 62,120 | 2030 | 31,060 | 50% | Designed for 1.5 degrees compatibility, validation pending |
| TGT-02 *(Example)* | Scope 3, categories 1, 4, 9, 12 and others | Absolute tCO2e | 306,400 | 2030 | 214,480 | 30% | Well-below 2 degrees, validation pending |
| TGT-03 *(Example)* | All scopes | Net zero | 368,520 | 2050 | Residual at most 10% of base year, neutralised by removals | At least 90% | Long-term target under the chosen standard |
| TGT-04 *(Example)* | Electricity | Renewable share, market-based | 46% (2024) | 2030 | 90% | | Supports TGT-01 |

Target standard: [name, version and date]. *Example:* The SBTi Corporate Net-Zero Standard: Version 2.0 was published in 2026 and the SBTi transition table allows submissions under Version 1.3.1 until 2027-01-31, under either version from 2027-02-01 to 2028-01-31, and only under Version 2.0 from 2028-02-01. Check the current criteria at sciencebasedtargets.org before submission.

Use of carbon credits: [state whether credits count toward targets]. *Example:* Credits are not counted toward TGT-01 or TGT-02; removals are used only for residual emissions under TGT-03.

## 5. Operational levers and pathway, Scope 1 and 2

<!-- Guidance: List each lever with owner, timing, abatement against business as usual and cost. Check that the levers close the gap to the target. Pitfall: counting the same tonne twice, for example a heat pump and a renewable tariff both claiming the same electricity. -->

Business as usual (BAU) assumes production growth of 1.5% a year on FY2026 emissions, as simple (not compounded) growth, with no new levers: 51,551 x 1.06 = 54,644 tCO2e in 2030 *(Example)*. The gap to TGT-01 is 54,644 - 31,060 = 23,584 tCO2e.

| Lever ID | Lever | Owner | Start | Full effect | Abatement 2030 vs BAU, tCO2e | Capex EUR m | Simple capex per tonne, EUR |
|---|---|---|---|---|---|---|---|
| L1 *(Example)* | Renewable power purchase agreement covering 75% of Lodz load | CPO and Lodz plant manager | 2028 | 2028 | 15,540 | 0 (opex premium EUR 0.9 m a year) | 58 a year (opex) |
| L2 *(Example)* | Industrial heat pumps replacing gas dryers at Zwolle (30,000 MWh gas), extra electricity covered by guarantees of origin | Zwolle plant manager | 2029 | 2030 | 5,490 | 14.0 | 255 |
| L3 *(Example)* | Electrify 40% of the delivery fleet | Fleet manager | 2027 | 2030 | 1,543 | 6.2 | 402 |
| L4 *(Example)* | Replace R-410A chillers with low-GWP units | Maintenance lead | 2027 | 2027 | 208 | 0.4 | 192 |
| L5 *(Example)* | Heat recovery and compressed air efficiency, 8% of the gas not replaced by L2 (82,000 MWh) | Plant managers | 2027 | 2028 | 1,200 | 2.1 | 175 |
| **Total** | | | | | **23,981** | **22.7** | |

Abatement is estimated at FY2026 activity levels, and L5 excludes the Zwolle dryer gas that L2 removes, so no tonne is counted twice. Simple capex per tonne is capex divided by ten years of full-year abatement, before energy cost changes; use the investment appraisal for decisions. Residual 2030 = 54,644 - 23,981 = 30,663 tCO2e, below the TGT-01 value of 31,060 by 397 tCO2e *(Example)*. L2 adds about 10,000 MWh of electricity at Zwolle: its location-based effect is smaller than its market-based effect, and both are disclosed.

| Year | BAU tCO2e | Lever abatement | Planned emissions | Linear path to TGT-01 | On path? |
|---|---|---|---|---|---|
| 2027 *(Example)* | 52,324 | 1,194 | 51,130 | 46,590 | No, PPA starts 2028 |
| 2028 *(Example)* | 53,098 | 17,720 | 35,378 | 41,413 | Yes |
| 2029 *(Example)* | 53,871 | 20,850 | 33,021 | 36,237 | Yes |
| 2030 *(Example)* | 54,644 | 23,981 | 30,663 | 31,060 | Yes |

```mermaid
xychart-beta
  title "Quillfen Scope 1 and 2 market-based, tCO2e (Example)"
  x-axis [2024, 2026, 2027, 2028, 2029, 2030]
  y-axis "tCO2e" 0 --> 65000
  bar [62120, 51551, 51130, 35378, 33021, 30663]
  line [62120, 51767, 46590, 41413, 36237, 31060]
```

The bars show actual and planned emissions; the line is the straight path from the base year to TGT-01 (51,767 in 2026).

## 6. Value-chain levers, Scope 3

<!-- Guidance: Scope 3 levers depend on suppliers and customers. State what the organisation controls (specifications, purchasing, design) and how influence is exercised. Pitfall: claiming reductions that come only from better data. -->

BAU Scope 3 in 2030 at 1.5% simple growth a year: 278,340 x 1.06 = 295,040 tCO2e; gap to TGT-02: 295,040 - 214,480 = 80,560 tCO2e *(Example)*.

| Lever ID | Lever | Category | Owner | Abatement 2030 vs BAU, tCO2e | Dependency |
|---|---|---|---|---|---|
| S3-L1 *(Example)* | Higher recycled fibre content and lighter board grades | 1 | CPO and product development | 42,000 | Customer acceptance of grade changes |
| S3-L2 *(Example)* | Supplier programme: top 20 suppliers (70% of category 1) set their own targets and share product data | 1 | CPO | 24,000 | Supplier capacity; physical reductions only, data improvements are excluded |
| S3-L3 *(Example)* | Rail and intermodal transport for long routes | 4, 9 | Logistics director | 6,500 | Rail slot availability |
| S3-L4 *(Example)* | Design for recycling of flexible packaging (mono-material films) | 12 | Product development | 9,000 | Collection and sorting infrastructure in customer markets |
| **Total** | | | | **81,500** | |

Residual 2030 Scope 3 = 295,040 - 81,500 = 213,540 tCO2e, below the TGT-02 value of 214,480 *(Example)*. The margin of 940 tCO2e is thin: section 11 sets the contingency.

## 7. Financial planning

<!-- Guidance: Show the money: capex and opex by lever and year, how it is funded, and whether it is in the approved budget. Disclose capex that supports fossil-fuel activities separately. Pitfall: a plan whose capex is not in the budget. -->

| Lever | 2027 | 2028 | 2029 | 2030 | Total capex EUR m | In approved budget? |
|---|---|---|---|---|---|---|
| L2 *(Example)* | 1.0 | 6.0 | 7.0 | 0 | 14.0 | 2027 only; later years in the medium-term plan |
| L3 *(Example)* | 1.5 | 1.5 | 1.6 | 1.6 | 6.2 | Yes |
| L4 *(Example)* | 0.4 | 0 | 0 | 0 | 0.4 | Yes |
| L5 *(Example)* | 1.2 | 0.9 | 0 | 0 | 2.1 | Yes |
| **Total** | **4.1** | **8.4** | **8.6** | **1.6** | **22.7** | |

| Item | Value |
|---|---|
| Opex for the plan *(Example)* | PPA premium EUR 0.9 m a year from 2028; supplier programme EUR 0.3 m a year |
| Funding *(Example)* | Operating cash flow and the sustainability-linked revolving credit facility; green loan considered for L2 |
| EU Taxonomy alignment *(Example)* | L2 and L3 assessed against the Taxonomy climate delegated act criteria; result in the Taxonomy report |
| Capex in fossil-fuel assets, internal view *(Example)* | EUR 0.8 m a year maintenance on gas boilers at Lodz and Ohio until replacement. ESRS E1 paragraph 12(b) asks only for capex in coal, oil and gas economic activities listed by NACE code, which Quillfen does not carry out |
| Share of total capex for the plan *(Example)* | 2027: EUR 4.1 m of EUR 38 m group capex (10.8%) |

Each lever above EUR 1 million passes through a capex request with the internal carbon price applied (section 2).

## 8. Locked-in emissions

<!-- Guidance: Estimate future emissions from existing assets and products over their remaining life, and say how they threaten the targets. Pitfall: ignoring long-lived assets because they are already depreciated. -->

Locked-in emissions are future emissions committed by key assets and products already in place. The amended ESRS E1 asks for a qualitative explanation of how they could put the plan's targets at risk; a quantified estimate makes the explanation testable.

| Asset ID | Asset | Annual tCO2e | Remaining life | Locked-in tCO2e | Planned action |
|---|---|---|---|---|---|
| LCK-01 *(Example)* | Gas boilers, Lodz (40,000 MWh gas a year) | 7,320 | 12 years (to 2038) | 87,840 | Option study for electrification by 2032, which would cut this to 43,920 |
| LCK-02 *(Example)* | Gas boilers, Ohio (22,000 MWh gas a year) | 4,026 | 8 years (to 2034) | 32,208 | Replace at end of life with electric boilers |
| **Total** | | **11,346** | | **120,048** | |

Product lock-in: [describe products whose use or end of life commits emissions]. *Example:* Multi-layer flexible films that cannot be recycled commit end-of-life emissions in category 12; S3-L4 addresses them.

## 9. Assumptions, dependencies and scenarios

<!-- Guidance: List the assumptions that, if wrong, break the plan, and the external dependencies. Say which climate scenario the targets and pathway are consistent with. Pitfall: assumptions that differ from those in the financial statements. -->

| Assumption ID | Assumption | Value used | Sensitivity | Consistent with financial statements? |
|---|---|---|---|---|
| ASM-01 *(Example)* | Production growth | 1.5% a year | 3% a year adds about 3,000 tCO2e to 2030 BAU Scope 1 and 2 | Yes, same as budget |
| ASM-02 *(Example)* | Polish grid decarbonisation | Not relied on (market-based PPA used) | Location-based figure improves if the grid decarbonises | Yes |
| ASM-03 *(Example)* | Gas price | [Source and value] | Heat pump payback | Yes, same as impairment test |
| ASM-04 *(Example)* | Carbon price exposure | Not in EU ETS today; fuel pricing under the separate EU ETS for buildings and road transport assumed from its start date (check the current date) | Raises fleet and heating costs | Check national application date |

| Dependency ID | Dependency | Owner | Mitigation |
|---|---|---|---|
| DEP-01 *(Example)* | Grid connection upgrade at Zwolle for L2 | Zwolle plant manager | Application filed; L2 phased |
| DEP-02 *(Example)* | Supplier capacity for recycled fibre | CPO | Two-supplier policy |
| DEP-03 *(Example)* | Customer acceptance of lighter grades | Commercial director | Joint testing programme |

Scenario consistency: [name the scenarios]. *Example:* Targets were checked against a 1.5 degrees, low-overshoot pathway and a current-policies pathway; the scenario analysis itself is documented in the climate risk assessment.

## 10. Workforce, suppliers and stakeholders

<!-- Guidance: Explain how the transition affects people and how they are involved: reskilling, job changes, supplier support, customers and communities. Pitfall: a plan that is silent on the people who operate the assets being replaced. -->

| Group | Effect of the plan | Engagement | Commitment |
|---|---|---|---|
| Boiler and dryer operators, Zwolle *(Example)* | Roles change with heat pumps | Works council consultation | Retraining for all 14 operators before commissioning |
| Fleet drivers *(Example)* | Electric vehicle operation and charging | Training and pilot | No redundancies from fleet electrification |
| Top 20 suppliers *(Example)* | Asked to set targets and share data | Supplier days, scorecards | Technical support and longer contracts for leaders |
| Customers *(Example)* | Lighter grades, mono-material films | Joint development | Shared product carbon data |
| Local communities *(Example)* | Grid upgrades, traffic changes | Site open days | Annual update |

## 11. Risks to delivery and contingency

<!-- Guidance: List what could stop the plan and the fallback for each. Pitfall: a contingency that relies on buying offsets. -->

| Risk ID | Risk | Lever affected | Likelihood | Impact tCO2e 2030 | Contingency |
|---|---|---|---|---|---|
| TR-01 *(Example)* | PPA counterparty or price not secured | L1 | Medium | 15,540 | Bundled renewable tariff with certificates from the same market as fallback |
| TR-02 *(Example)* | Grid connection delay | L2 | Medium | 5,490 | Electrode boiler pilot; phased commissioning |
| TR-03 *(Example)* | Supplier programme slower than planned | S3-L2 | High | Up to 24,000 | Prioritise the five largest suppliers; procurement criteria from 2028 |
| TR-04 *(Example)* | Acquisition adds emissions | All | Medium | Depends on deal | Base year recalculation policy GHG-2026 section 4; transition review in the integration plan |

Contingency rule: if planned emissions exceed the linear path for two consecutive years after 2028, the board sustainability committee requires a recovery plan within 90 days.

## 12. Monitoring and reporting cycle

<!-- Guidance: Define the KPIs, their frequency and who reports them, and how the plan is updated. Pitfall: tracking only annual emissions, which arrive too late to act. -->

| KPI ID | KPI | Frequency | Source | Owner | 2030 value |
|---|---|---|---|---|---|
| KPI-01 *(Example)* | Scope 1 and 2 market-based tCO2e | Quarterly estimate, annual assured | GHG inventory | GHG inventory lead | 31,060 or lower |
| KPI-02 *(Example)* | Renewable electricity share | Quarterly | Energy portal | Energy buyer | 90% |
| KPI-03 *(Example)* | Gas MWh per tonne produced | Monthly | Site meters | Plant managers | [Value] |
| KPI-04 *(Example)* | Share of category 1 spend with supplier targets | Semi-annually | Supplier programme | CPO | 70% |
| KPI-05 *(Example)* | Plan capex spent vs budget | Quarterly | Finance | CFO | 100% of plan |

```mermaid
flowchart LR
  A["Annual inventory, assured"] --> B["Progress review vs pathway"]
  B --> C{"On path?"}
  C -->|"Yes"| D["Budget and capex update"]
  C -->|"No"| E["Recovery plan within 90 days"]
  E --> D
  D --> F["Board approval of updated plan"]
  F --> G["Disclosure in annual report"]
  G --> A
```

## 13. Disclosure mapping

<!-- Guidance: Map each section to the disclosure that uses it. Pitfall: a published summary that omits the capex or locked-in emissions the standards ask about. -->

| Plan section | ESRS E1 (as amended 2026) | IFRS S2 | Other |
|---|---|---|---|
| 1 Ambition, 1.5 degrees statement | E1-1 paragraph 12(a) and AR 2, including the explanation where targets are not 1.5 degrees compatible; paragraph 13 if no plan | Paragraph 14(a)(iv) and (v) | UK SRS S2 where adopted |
| 2 Governance | E1-1 paragraph 12(a), approval and embedding in strategy; ESRS 2 governance | Paragraphs 5 to 7 | |
| 4 Targets | E1-6 targets (revised numbering) | Paragraphs 33 to 36 | SBTi validation |
| 5 and 6 Levers | E1-1 paragraph 12(a) levers; E1-5 actions and resources | Paragraph 14(a)(i) to (iii) | |
| 7 Financial planning | E1-1 paragraph 12(a) investments and funding, 12(b) coal, oil and gas capex; EU Taxonomy disclosures | Paragraph 14(b), resourcing, and connectivity with financial statements | |
| 8 Locked-in emissions | E1-1 paragraph 12(d) | Not named; covered by assumptions and dependencies | |
| 9 Assumptions | E1-1 paragraph 12(c) | Paragraph 14(a)(iv), key assumptions and dependencies | |
| 12 Progress | E1-1 paragraph 12(e) | Paragraph 14(c) | |

ESRS paragraph numbers were checked against Delegated Regulation (EU) 2026/1563 as published in the Official Journal on 2026-09-21; IFRS S2 paragraph numbers are pointers to check against the official IFRS S2 text. The IFRS Foundation guidance "Disclosing information about an entity's climate-related transition, including information about transition plans, in accordance with IFRS S2" (June 2025) builds on the Transition Plan Taskforce material and is a useful reading aid; it does not change the standard.

## 14. Glossary and references

<!-- Guidance: Define terms once and keep the list of documents actually used. -->

| Term | Meaning in this template |
|---|---|
| Transition plan | The organisation's plan to align its business with its climate targets |
| Lever | An action that reduces emissions, such as electrification or a supply change |
| BAU | Business as usual: emissions without new levers |
| Locked-in emissions | Future emissions committed by existing assets and products over their life |
| Net zero | Reducing emissions as far as the chosen standard requires and neutralising the residual with removals |
| Internal carbon price | A price per tonne used in decisions, as a shadow price or internal fee |
| PPA | Power purchase agreement |

References:

- Commission Delegated Regulation (EU) 2023/2772 (ESRS), ESRS E1, as amended by Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (Official Journal 2026-09-21, in force 2026-11-10, applies to financial years beginning on or after 2027-01-01): https://eur-lex.europa.eu/eli/reg_del/2026/1563/oj
- Directive (EU) 2026/470 (Omnibus I) of 24 February 2026, published in the Official Journal on 2026-02-26, in force 2026-03-18; amends the CSRD and Directive (EU) 2024/1760 (CSDDD), and Article 4, point (16), deletes CSDDD Article 22: https://eur-lex.europa.eu/eli/dir/2026/470/oj
- IFRS S2 "Climate-related Disclosures" (ISSB, June 2023), paragraph 14; names and paragraph numbers only.
- IFRS Foundation, transition plan disclosure guidance (June 2025): https://www.ifrs.org/content/dam/ifrs/supporting-implementation/ifrs-s2/transition-plan-disclosure-s2.pdf
- SBTi Corporate Net-Zero Standard, Version 1.3.1 and Version 2.0 (2026), transition timeline: https://sciencebasedtargets.org/corporate-net-zero-v1
- GHG Emissions Inventory (`finance/ghg-emissions-inventory`) for the baseline and base-year policy.

## Standard and licence note

Based on EU law (ESRS E1 in Delegated Regulation (EU) 2023/2772 as amended by Delegated Regulation (EU) 2026/1563; Directive (EU) 2026/470), cited by number and paraphrased in original words; EU legal texts may be reused under Commission Decision 2011/833/EU and only the Official Journal text is authentic. IFRS S2 is cited by paragraph number only, because the IFRS Foundation restricts reproduction; SBTi, GHG Protocol and Transition Plan Taskforce materials are referred to by name. The structure, tables, pathway method and the Quillfen Packaging Group example are original and fictional. Check the current consolidated texts and validation criteria before use. Template licence: MIT.