Climate Transition Plan Template

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.

Document control

Approvals

Revision history

Contents

1. Purpose, basis and ambition
2. Governance and accountability
3. Baseline and emissions profile
4. Targets
5. Operational levers and pathway, Scope 1 and 2
6. Value-chain levers, Scope 3
7. Financial planning
8. Locked-in emissions
9. Assumptions, dependencies and scenarios
10. Workforce, suppliers and stakeholders
11. Risks to delivery and contingency
12. Monitoring and reporting cycle
13. Disclosure mapping
14. Glossary and references

1. Purpose, basis and ambition

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.

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

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

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

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

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.

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.

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

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).

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

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

8. Locked-in emissions

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.

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

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

11. Risks to delivery and contingency

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

13. Disclosure mapping

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

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.