CSDDDArticle 22EU

CSDDD climate transition plan Article 22 requirements

Article 22 requires in-scope companies to adopt, put into effect, and update a climate-change mitigation transition plan.

Use this page to check the required plan contents: strategy alignment, targets, decarbonisation actions, funding, governance roles, and 12-month progress updates.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

The CSDDD climate transition plan is the Article 22 plan for climate-change mitigation. Article 22 applies to companies in scope under Article 2(1) and (2): EU companies, non-EU companies, and ultimate parent groups that meet the Directive's employee, turnover, or franchising and licensing thresholds. For those companies, the plan should explain how the company's business model and strategy are intended, through best efforts, to align with a sustainable economy, limiting global warming to 1.5 C under the Paris Agreement, and the EU climate-neutrality objective. Treat it as an operating plan with evidence, owners, and updates, not as a one-time sustainability statement.

Section 1

What Article 22 requires

Article 22 applies to companies covered by the CSDDD scope provisions in Article 2(1) and 2(2), including EU companies, non-EU companies, and ultimate parent companies that meet the Directive's thresholds. The core duty is to adopt and put into effect a transition plan for climate-change mitigation.

The plan must aim, through best efforts, to make the company's business model and strategy compatible with the transition to a sustainable economy, limiting global warming to 1.5 C in line with the Paris Agreement, and the EU climate-neutrality objective under Regulation (EU) 2021/1119. Where relevant, it should also address exposure to coal-, oil-, and gas-related activities.

  • Confirm the legal entity or group entity that is in scope before assigning Article 22 ownership.
  • State how the business model and strategy will change, not only how emissions will be reported.
  • Connect the plan to the company's product and service portfolio, capital allocation, technology choices, and fossil-fuel exposure where relevant.
  • Keep Article 22 separate from general due diligence risk registers, while cross-linking the evidence where climate actions affect operations, subsidiaries, or chains of activities.
Sources for this answer
Directive (EU) 2024/1760, Article 22
Binding CSDDD text for the duty to adopt and put into effect a climate-change mitigation transition plan.
European Commission CSDDD overview
Commission overview describing the Directive's due-diligence duty and climate transition-plan obligation for large companies.
Section 2

Minimum plan contents

Article 22 lists the design elements that should be visible in the plan. A defensible plan should make each element easy to find and should avoid replacing the required plan contents with general climate ambition language.

The target section should include time-bound climate targets for 2030 and in five-year steps up to 2050. Where appropriate, it should include absolute greenhouse gas emission-reduction targets for scope 1, scope 2, and scope 3 emissions for each significant category.

  • Targets: time-bound climate targets for 2030 and five-year intervals up to 2050, based on conclusive scientific evidence.
  • Emissions: absolute reduction targets for scope 1, scope 2, and scope 3 greenhouse gas emissions where appropriate and for each significant category.
  • Levers and actions: identified decarbonisation levers and planned key actions, including product or service portfolio changes and new technologies where appropriate.
  • Funding: explanation and quantification of investments and funding supporting implementation.
  • Governance: the role of administrative, management, and supervisory bodies in the transition plan.
Sources for this answer
Directive (EU) 2024/1760, Article 22
Article 22(1) source for required target, decarbonisation, funding, and governance content.
Section 3

Annual update and progress evidence

Article 22 is not satisfied by leaving the plan unchanged after approval. Member States must ensure that the transition plan is updated every 12 months and includes a description of progress toward the plan's climate targets.

The update should be structured so a reviewer can compare last year's targets, actions, investment assumptions, and governance decisions against current progress. Where progress falls short, the evidence should explain whether the issue is data quality, capital allocation, operating execution, technology availability, portfolio change, or a revised assumption.

  • Maintain a versioned plan with approval date, reporting period, responsible body, and change log.
  • Track progress against each 2030 and five-year target, not only against aggregate emissions.
  • Record delivery status for each key decarbonisation action and investment line.
  • Capture management or board decisions when targets, actions, funding, or assumptions change.
  • Keep the annual Article 22 update linked to any sustainability reporting that the company uses for deemed adoption.
Sources for this answer
Directive (EU) 2024/1760, Article 22
Article 22(3) source for the 12-month update and progress-description requirement.
Recommended next step

Turn Article 22 into a maintained evidence file

Map the CSDDD transition-plan requirement to targets, actions, funding, governance decisions, and 12-month progress evidence before the next approval cycle.

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Section 4

Reporting overlap and group plans

Article 22 contains a deemed-compliance mechanism for adoption of the plan. Companies reporting a climate-change mitigation transition plan under Article 19a, 29a, or 40a of Directive 2013/34/EU are deemed to have complied with the Article 22 obligation to adopt a plan.

That deemed adoption does not remove the practical need to put the plan into effect and update it. If a company is included in a parent undertaking's reported transition plan, the subsidiary should keep evidence that the parent plan has been adapted to its own business model and strategy where Article 22 requires that alignment.

  • Identify whether the company has its own reported transition plan or relies on a parent undertaking's plan.
  • Check that the reported plan covers the Article 22 design elements, rather than only climate reporting metrics.
  • For group reliance, document which legal entities are covered and how the plan fits each relevant business model and strategy.
  • Do not cite draft guidance, voluntary frameworks, or ESRS implementation material as binding CSDDD law unless the source status is stated clearly.
Sources for this answer
Directive (EU) 2024/1760, Article 22
Article 22(2) source for deemed adoption through transition-plan reporting under Directive 2013/34/EU.
Section 5

Governance and supervisory evidence

The plan should show who governs climate-transition decisions, not only who prepares the document. Article 22 requires a description of the role of administrative, management, and supervisory bodies, and Article 25 requires supervisory authorities to supervise the adoption and design of the plan.

Useful evidence therefore includes both governance design and governance activity: the committee or body responsible, the matters it reviewed, the decisions it made, and the way those decisions changed targets, actions, funding, or implementation.

  • Board or management body approval record for the plan and annual update.
  • Terms of reference or responsibility matrix showing administrative, management, and supervisory body roles.
  • Minutes or decision logs for target approval, decarbonisation actions, funding, and significant assumption changes.
  • Evidence pack connecting plan design to data sources, scientific basis, emissions categories, investment assumptions, and implementation owners.
  • Regulator-response file covering information requests or investigation material related to Article 22 adoption and design.
Sources for this answer
Directive (EU) 2024/1760, Article 22
Article 22(1)(d) source for governance-body role descriptions in the plan.
Directive (EU) 2024/1760, Article 25
Article 25 source for supervisory authority oversight of adoption and design of Article 22 plans.
Section 6

Common failure points

The main content risk is publishing a climate narrative that does not contain the Article 22 design elements. The main evidence risk is approving a plan without a repeatable update process that can show progress every 12 months.

A strong Article 22 file ties each claim to a plan section, owner, source, dataset, governance decision, and next update trigger.

  • Using net-zero language without showing business-model and strategy compatibility.
  • Listing targets without the required 2030 and five-year structure up to 2050.
  • Omitting scope 3 categories where they are significant and an absolute target is appropriate.
  • Describing decarbonisation levers without planned actions, funding, or portfolio implications.
  • Treating sustainability-reporting deemed adoption as the end of the Article 22 operating duty.
  • Keeping board evidence separate from the transition-plan evidence pack.
Sources for this answer
Directive (EU) 2024/1760, Article 22
Article 22 source for the plan elements that common failure points should be checked against.
Primary sources

References and citations

Directive (EU) 2024/1760, Article 22
eur-lex.europa.eu
Referenced sections
  • Article 22 source for the plan elements that common failure points should be checked against.
"time-bound targets related to climate change for 2030"
Directive (EU) 2024/1760, Article 25
eur-lex.europa.eu
Referenced sections
  • Article 25 source for supervisory authority oversight of adoption and design of Article 22 plans.
"supervise the adoption and design of the transition plan"
European Commission COM(2025)80 proposal
commission.europa.eu
Referenced sections
  • Commission proposal source retained only as status context for possible date changes; this page does not rely on it for binding Article 22 plan contents.
"postpones the entry into application of the CSDDD"
European Commission CSDDD overview
commission.europa.eu
Referenced sections
  • Commission overview describing the Directive's due-diligence duty and climate transition-plan obligation for large companies.
"adopt and put into effect, through best efforts, a transition plan"
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