AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024.

This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports. Below you will a summary of the key findings related to ESRS E1 Climate change.

We strongly recommend that you use the IRO E plan in Cleerit ESG to structure your information on E1 IROs, policies, actions and targets, before including these tables into the datapoints in the ESRS templates. We also recommend that you set up a specific governance model in Cleerit to structure and report on your transition plan by decarbonisation lever. This will ensure that you structure the information as expected by the financial market. Don’t hesitate to contact us if you need further guidance on this point.

E1 Transition plans

There is an overall improvement as compared to previous non-financial statements in terms of quality and comparability (use of denominations, consistency, etc.) which highlight the added value of the ESRS.

None of the transition plans (TPs) covered in the sample can be considered compliant with all ESRS data points.

Beyond the mere “tick-the-box” exercise, AMF assessed whether TPs manage to convey a sense of the broader undertaking’s strategy which is consistent throughout the report.

In this respect major difficulties are still present in the TPs’ building blocks:

• target-setting;
• decarbonisation levers;
• financial resources.

« Net-zero » targets and « GHG neutrality » claims (E1-7)

Some improvements are identified compared to previous non-financial statements: some companies deleted unclear claims from previous reports and show considerable efforts in adjusting to the ESRS framework (for example, the 90-95% reduction pathway with the possibility for justified sectoral variations, associated with a Net-Zero target).

However, there is still a lot of confusion with the use of the following concepts:

Net Zero claims, which are very popular (probably due to extensive use of SBTi external validation) are undermined by 3 types of breaches:

• Not respecting the 90-95% reduction ambition, in both absolute and gross value.
• Not covering the scope of GHG emissions, especially along the value chain (3 Scopes).
• Dealing with residual emissions (5-10%): disclosures tend to be succinct or inexistant. Some issuers explain that the action plans to neutralize residual emissions are not yet fully defined.

The use of GHG neutrality claims (although less common) also raises questions:

• Confusion with the net-zero claim (or transition plans).
• Lack of reporting associated with the claim: cf. the 3 items of §61 of E1-7 which are important to understand the consistency of the claim with E1-4 targets and their reliance on the use of carbon credits.

AMF recommends preserving the “net-zero” concept in the revised ESRS (with a minimum 90-95% GHG reduction pathway), which the ESRS has helped to strengthen, while clarifying some aspects such as the options available for residual emissions (carbon credits + removals) and the different types of removals (transfer of CO2).

AMF recommends clarifying the expectations around “carbon neutrality claims”: emission reductions vs use of carbon credits and removals; target-setting (all Scopes, etc.) – thereby clarify the interactions between the two notions. 

Reporting on GHG emissions reduction targets

A few surprising shortcomings with regards to clear ESRS expectations:

• Although rare, AMF still finds some targets set in intensity value for non-financial institutions. In this case, the associated absolute value is not always (clearly) displayed. For financial institutions, targets are usually set in intensity and sector-by-sector (except for fossil fuels).
• Gross value reporting: some undertakings are setting targets in net value (taking into account removals or credits), either explicitly (rare) or implicitly. In the latter case, the information on the use of carbon credits or removals is not easy to spot.

Overall, there seems to remain some confusion around the identification of actions that are eligible as GHG reduction levers under E1-4 compared to actions that should be excluded from these targets (carbon credits, removals, avoided emissions, cf. section on E1-7).

Some companies do not make a clear distinction between GHG emission reduction in their value chain (reported under E1-4) and emissions associated with carbon credits or removals (to be reported under E17) – they are netting these different types of emissions.

This is not compliant with the requirements in E1-4 to set targets in gross value, by excluding emissions associated with removals, carbon credits and avoided emissions.

Depending on the tool used, different reporting requirements are expected: E1-4 for very specific types of removals (transfer of CO2 into geological storage) vs E1-7 for other removal and carbon credits mechanisms.

Scope 3: undertakings could also be clearer on the consistency between the scope of their targets (E1-4) and their GHG inventory boundaries (E1-6) as climate targets are sometimes set on a limited number of Scope 3 categories.

For financial undertakings, AMF is still seeing significant differences in the scope of reporting from one financial institution to the other

More generally, climate reporting tends to lack explanations around the methodology used to set targets:

• Are they derived from a sectoral decarbonisation pathway?
• What are the underlying scenarios?
• Justification of the reference year; explanations on the consideration of future developments, etc.).

Good practice

Use of the “AR 48 table” that puts into perspective the GHG inventory (including Scope 3 Categories) with the entity’s targets. 

Decarbonisation levers

Qualitative description

Practices tend to be heterogenous with some companies displaying a simple list of items while others strive to be more granular (for instance, separating actions taken from actions planned for the future) and comply with MDR-A requirements [on actions] .

Overall, the latter [MDR-A] tend to be missing (time horizons, clear scope, expected outcomes…).

Financial resources allocated to the transition plan

Information on the nature and the amounts of CapEx/OpEx allocated to the transition plan is identified as the most difficult step to be taken by companies on transition planning.

This leads to various types of reporting practices (including good practices):

• Detailed reporting by lever, by type of expenditure (Human, CapEx, Opex) and for both planned and future resources across different time horizons
• Detailed reporting for part of the requirements (resources already planned)
• Aggregated reporting: a few overall figures (x billion in low-carbon overall actions)
• No quantitative reporting but with justifications: non-materiality or challenges to disentangle low carbon investments from general Capex
• No reporting at all on financial resources

AMF noticed very few elements of reconciliation between the resources associated with the transition plan (if any– see point above) and the financial statements.

Source: https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf

When you use Cleerit ESG to structure your E1 disclosures on transition plans, IROs and PATs you increase both ESRS compliance and organizational efficiency. Contact us if you are interested in learning more >>>.