{"id":1266,"date":"2024-09-23T12:35:00","date_gmt":"2024-09-23T10:35:00","guid":{"rendered":"https:\/\/materiality.astrotea.pl\/?p=1266"},"modified":"2025-12-03T19:19:09","modified_gmt":"2025-12-03T18:19:09","slug":"balancing-with-transition-plans","status":"publish","type":"post","link":"https:\/\/materiality.pl\/en\/wiedza-i-praktyka\/balagan-z-planami-transformacji\/","title":{"rendered":"The mess with transformation plans"},"content":{"rendered":"

First, a few words about regulatory chaos. Article 19a(1)(a)(iii) of the CSRD Directive refers to the need to report on the transition plan to a sustainable economy. The ESRS standards define two separate concepts: transition plan and climate change mitigation transition plan. Most often, discussions with experts involved in sustainability reporting concern the latter plan, as the disclosure requirements are described in detail in disclosure requirement E1-1. However, we also have disclosure requirement E4-1 concerning the transition plan for biodiversity and ecosystems and the integration of biodiversity and ecosystems into the strategy and business model. On top of that, we have the CSDDD directive, which in Article 22 refers to the climate change transition plan. In the English original, the plan in the ESRS standards and the one in the CSDDD have the same name: transition plan for climate change mitigation<\/em> \u2013 so it's the same thing, unfortunately the European Commission's translation services have once again failed to impress.<\/p>\n\n\n\n

The Due Diligence Directive requires companies covered by it to adopt and implement a transition plan to mitigate climate change \u2013 so we have an obligation to take specific actions. The CSRD Directive and, following it, the ESRS standards do not require any action, they only contain reporting obligations. All elements of disclosure requirement E1-4 described in paragraph 16 of ESRS E1 apply only when such a plan exists. If we do not have a transition plan, we use the provision of paragraph 17: we disclose whether we intend to adopt such a plan and, if so, when.<\/p>\n\n\n\n

In addition to the confusion in the regulations themselves, we also unfortunately have disorder in the area of support for companies. Creating transformation plans and reporting on them is complicated, so on the initiative of the European Commission, work is currently underway on documents to clarify these tasks. Unfortunately, instead of a coherent approach, we will receive three (actually four) documents:<\/p>\n\n\n\n