Is a climate transition plan still required by CSDDD?

The original Directive (EU) 2024/1760 required certain in-scope companies to adopt and put into effect a climate transition plan for climate-change mitigation. The plan was to pursue, through best efforts, compatibility with a sustainable economy, the Paris Agreement 1.5 C limit, and EU climate neutrality, including intermediate and 2050 targets.

Historical Article 22 required time-bound 2030 targets and five-year steps to 2050, appropriate Scope 1, Scope 2, and Scope 3 absolute emissions-reduction targets, decarbonisation levers and key actions, quantified investment and funding, and the role of administrative, management, and supervisory bodies. It also required an update every 12 months with progress against targets. Directive (EU) 2026/470 entered into force on 18 March 2026 and states that Article 22 is deleted.

Member States must transpose the CSDDD-related 2026 amendments by 26 July 2028 and apply them from 26 July 2029. The amended CSDDD does not require Member States to impose the former standalone Article 22 duty. A national law may still contain a climate-plan obligation on another basis, including an earlier or separate national measure, so the company must check the law that applies to it.

Yes. Deleting CSDDD Article 22 answers only the CSDDD question. A company may still need a plan, plan disclosure, targets, or progress reporting under the Corporate Sustainability Reporting Directive and applicable European Sustainability Reporting Standards, national climate or corporate law, sector regulation, lending or investment terms, procurement conditions, or a public commitment.

Keep the legal tests separate. ESRS E1-1 is a disclosure requirement concerning a transition plan for climate-change mitigation; it does not recreate the former CSDDD duty for every company. Whether ESRS E1-1 applies depends on the reporting entity's current CSRD scope, the applicable reporting period and standards, and its materiality assessment. A contractual or voluntary plan may also use different boundaries, targets, governance, and assurance.

Do not delete the plan or its evidence merely because Article 22 was removed. First identify every remaining basis for the control. Then relabel the owner, evidence, update cycle, and assurance statement so each one points to the rule, contract, or commitment that still requires it.

If no other basis remains, record the legal change and retire the CSDDD-specific obligation in a controlled way. Preserve historical decisions and public statements that still need an audit trail, and correct any current statement that says the amended CSDDD itself requires the plan.