Questions & Answers
Is the understanding correct that undertakings can add the amount of emissions reduced before their new base year to the actual emissions of the new base year and therefore suggest that the past emissions have not been realised?
- Climate-related targets
- progress
Background
ESRS E1 paragraph 34 states: ‘If the undertaking has set GHG emission reduction targets, ESRS 2 MDR-T and the following requirements shall apply …
(c) the undertaking shall disclose its current base year and baseline value, and from 2030 onwards, update the base year for its GHG emission reduction targets after every five-year period thereafter. The undertaking may disclose the past progress made in meeting its targets before its current base year provided that this information is consistent with the requirements of this Standard …’.
ESRS E1 paragraph AR 25 states: ‘When disclosing the information required under paragraph 34(c) on base year and baseline value: …
(d) when presenting climate-related targets, the undertaking may disclose the progress in meeting these targets made before its current base year. In doing so, the undertaking shall, to the greatest extent possible, ensure that the information on past progress is consistent with the requirements of this Standard. In the case of methodological differences, for example, regarding target boundaries, the undertaking shall provide a brief explanation for these differences.’
Answer
No, an undertaking cannot add the amount of emissions reduced before its new base year to the actual emissions of the new base year and therefore suggest that the past emissions have not been realised.
While undertakings may disclose the progress done in meeting these targets before their current base year, when doing it undertakings may disclose quantitative and qualitative information, e.g. disclosure of the amount of the emissions reduced, an explanation in case of methodological differences, an explanation of the alignment with the requirements of the E1 Standard, etc. However, it is not allowed to add previous emission reductions achieved to the new base year emissions, which shall be the ones effectively disclosed under the ESRS for the new base year (with no additions or subtractions).
It is important to note that, even if an undertaking cannot add the amount of emissions reduced before its new base year, this reduction might have an impact on the future targets set by the undertaking as it is linked to the sector emission reduction path.
For example, assuming that the current (new) base year is 2025, the amount of reductions in Y-1 (i.e. 2024) cannot be added to the 2025 base year as displayed in the following table.
Relations
Paragraph | Content |
|---|---|
when presenting climate-related targets, the undertaking may disclose the progress in meeting these targets made before its current base year. In doing so, the undertaking shall, to the greatest extent possible, ensure that the information on past progress is consistent with the requirements of this Standard. In the case of methodological differences, for example, regarding target boundaries, the undertaking shall provide a brief explanation for these differences. | |
the undertaking shall disclose its current base year and baseline value, and from 2030 onwards, update the base year for its GHG emission reduction targets after every five-year period thereafter. The undertaking may disclose the past progress made in meeting its targets before its current base year provided that this information is consistent with the requirements of this Standard; | |
when presenting climate-related targets, the undertaking may disclose the progress in meeting these targets made before its current base year. In doing so, the undertaking shall, to the greatest extent possible, ensure that the information on past progress is consistent with the requirements of this Standard. In the case of methodological differences, for example, regarding target boundaries, the undertaking shall provide a brief explanation for these differences. | |
the undertaking shall disclose its current base year and baseline value, and from 2030 onwards, update the base year for its GHG emission reduction targets after every five-year period thereafter. The undertaking may disclose the past progress made in meeting its targets before its current base year provided that this information is consistent with the requirements of this Standard; | |
when presenting climate-related targets, the undertaking may disclose the progress in meeting these targets made before its current base year. In doing so, the undertaking shall, to the greatest extent possible, ensure that the information on past progress is consistent with the requirements of this Standard. In the case of methodological differences, for example, regarding target boundaries, the undertaking shall provide a brief explanation for these differences. | |
the undertaking shall disclose its current base year and baseline value, and from 2030 onwards, update the base year for its GHG emission reduction targets after every five-year period thereafter. The undertaking may disclose the past progress made in meeting its targets before its current base year provided that this information is consistent with the requirements of this Standard; | |
when presenting climate-related targets, the undertaking may disclose the progress in meeting these targets made before its current base year. In doing so, the undertaking shall, to the greatest extent possible, ensure that the information on past progress is consistent with the requirements of this Standard. In the case of methodological differences, for example, regarding target boundaries, the undertaking shall provide a brief explanation for these differences. |