Policy Brief, Sustainability Risks and Opportunities

PB 3/2023: Climate transition plans: State of play in EU legislation and policy recommendations

  • Company transition plans (of real economy and financial market actors) have the potential to become a steering instrument for directing capital flows toward climate neutrality if systematically anchored in legislation.
  • This policy brief provides an overview of the guidance that EU-legislation (is likely to) provide on transition plans – including the sustainability disclosure regulations (CSRD and SFDR), the Sustainability Due Diligence Directive (CSDDD), the banking package (CRR and CRD), and the Solvency II review.
  • For transition plans to support the transition to climate neutrality, dissemination and accessibility, comparability, credibility, and scienced-based scenarios are key.
  • Therefore, the disclosure of transition plans (for companies in the real economy and the financial sector) should be mandated and the provisions of the currently negotiated legislation should build on the CSRD to ensure harmonization.
  • The further processes related to the CSDDD and the Banking Package/Solvency II will be crucial in terms of integrating accountability and oversight of transition plans into the legislation.
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