Climate transition plan: what BEGES, the CSRD and EmpCo require

If your company published its greenhouse gas emissions report (BEGES) in 2022 or 2023, it must renew it in 2026 or 2027, including the transition plan. This plan is required elsewhere in different forms: BEGES expects an action plan until the next report, with a quantified reduction volume; the CSRD climate standard, whose revised version appeared in the EU Official Journal on 21 September 2026, a strategy compatible with 1.5°C; and the EmpCo Directive, a plan verified by an independent expert behind every "net zero" target displayed to consumers.

Companies renewing their BEGES generally have a plan written for ADEME’s platform, which meets only part of a CSRD auditor’s expectations. Our analysis of 1,644 plans published since 2023 shows what they most often lack, and a quantified case involving a mid-sized industrial company shows how to move from an assessment to a plan that stands up.

1What is a climate transition plan?

A transition plan describes the path between today’s emissions and a time-bound target: selected measures, the reduction each brings, its cost, timetable and the person accountable for it.

An assessment, a target, a plan

The assessment, target and plan are often confused, although they answer 3 distinct questions. The emissions assessment says where we start, source by source. The target says where we want to go, for example an absolute emissions reduction by 2030 aligned with a pathway validated by the Science Based Targets initiative (SBTi). The plan says how we get there: which measures, how many tCO2e each, with what budget and by what date.

The European climate reporting standard provides a useful definition: a plan showing "how the undertaking intends to transform its strategy and business model" to make them compatible with a low-carbon economy. It therefore commits to investment and business model choices, far beyond a list of small environmental actions, explaining why the CSRD asks for details of its approval by administrative and management bodies.

SNBC 3 as the reference pathway

For a French company, the public reference is the third National Low-Carbon Strategy, adopted by decree on 16 July 2026. It sets 276 MtCO2e in 2030 for the whole country, compared with 359 in 2025, or -23% in 5 years, around 5% a year. It does not apply directly to companies, but the official BEGES method recommends positioning plan targets against it.

This method, published in 2022, still cites the previous strategy’s benchmarks, -40% between 1990 and 2030. SNBC 3 represents -49.5% between 1990 and 2030, from 547 to 276 MtCO2e: a plan written in 2026 benefits from referring to the new figure, and its sector’s pathway.

2BEGES: a quantified action plan until the next report

Since the 2019 Energy and Climate Law, BEGES goes beyond a snapshot of emissions. Companies with more than 500 employees, 250 overseas, attach a transition plan to the report, made public with it and updated every 4 years.

What the Environmental Code says

Article L. 229-25 requires a plan presenting "the objectives, means and actions envisaged", as well as actions carried out since the previous report. Article R. 229-47 sets its content:

• A review of past actions: what has been implemented since the previous report, and the results achieved.
• Actions and resources envisaged until the next report, presented separately for direct and indirect emissions.
• The overall expected reduction volume, for direct and indirect emissions.

The mandatory horizon is therefore short: 4 years, until the next report. For a company not subject to the CSRD, mandatory indirect emissions also extend only to purchased electricity, heat and steam: scope 3 is not required, and a compliant plan may ignore purchasing, despite it often being the largest footprint source. Companies publishing their assessment and plan in their CSRD sustainability report are exempt from BEGES, provided they describe their activities in France.

What the official method additionally expects

The ministry’s regulatory method, version 5, specifies expectations. It requires quantified targets over 2 horizons, the next report and the long term, for example 2030 and 2050, and, for every action, at least the human and financial resources committed. It recommends estimating the effect of the costliest actions using ADEME’s quantification method, including actions improving carbon accounting itself, and distinguishing changes in the assessment arising from actions from those arising from activity.

We compared these expectations with published plans using ADEME’s open dataset. Of the 1,644 BEGES reports submitted under method version 5 by companies subject to the requirement between February 2023 and September 2026, 26% announce no reduction volume, despite this being required by the Code, almost half have no quantified target for 2030, and the "actions and resources" section mentions a euro amount in 3% of cases.

Inspection and penalties

No third party verifies BEGES: the regional prefect, together with the regional council president, identifies published reports and checks compliance, including the plan. In case of a breach, the prefect serves the company with formal notice, then may impose a fine of up to €50,000, €100,000 for a repeat offence, and make it public. Since the 2023 Green Industry Law, a public buyer may also exclude a company that has not prepared its report from a contract, in addition to the environmental criterion now scored in every procurement.

3CSRD: ESRS E1 requires a strategy compatible with 1.5°C

In the sustainability report required by the CSRD (Corporate Sustainability Reporting Directive), the transition plan is the subject of the first requirement in European climate standards, ESRS E1-1. Its ambition is different: showing that company strategy is compatible with the Paris Agreement’s 1.5°C limit and EU climate neutrality in 2050.

Who publishes, and for which financial year

The Omnibus Directive of 24 February 2026 restricts the CSRD to companies with more than 1,000 employees and €450 million in turnover, once transposed, by 19 March 2027 at the latest; as of 28 September 2026, French law has not changed. The revised standards, published on 21 September 2026 by Delegated Regulation (EU) 2026/1563, apply to financial years beginning from 1 January 2027, and optionally from 2026. Our articles on CSRD after Omnibus and CSR requirements by size detail the scope.

The 5 required elements

The revised standard requires publication of:

• The plan’s main characteristics: reduction targets, decarbonisation measures, key actions, investments and funding, approval by administrative and management bodies, consistency with strategy.
• The financial year’s investments relating to coal, oil and gas, if any.
• The main assumptions and dependencies underpinning the plan.
• A qualitative assessment of locked-in emissions, those committed for years by existing equipment or products.
• Progress made in its implementation.

The company also states whether its targets are compatible with 1.5°C, explaining any gap if they are not, and provides financial resources allocated to the plan, with an indicative range for coming years. The standard does not require adoption of a plan: a company without one declares this and states whether it intends to adopt one, and by when. The climate section is certified by a statutory auditor or an independent third-party body, alongside the rest of the report, and a Bilan Carbone® can underpin its quantification.

What changes compared with 2023

The 2023 version listed 10 elements; the revision retains 5. The alignment plan with the EU taxonomy and mention of exclusion from "Paris Agreement" benchmarks disappear. Assumptions and dependencies appear: deployment of a technology, available workforce, ability to change the value chain or expected regulatory developments, all conditions for success that the company does not control alone.

4EmpCo: a displayed "net zero" target must rest on a verified plan

Directive (EU) 2024/825, known as EmpCo for "Empowering Consumers", governs commercial communication to consumers, particularly any claim about future environmental performance, whether relating to a product or the company: "net zero in 2040", "-50% by 2030", "carbon neutral in 2050".

What the directive says

It considers such a claim misleading if it is not supported by "clear, objective, publicly available and verifiable" commitments set out in a detailed and realistic implementation plan. This plan includes measurable, time-bound targets and the elements needed to achieve it, such as resource allocation; it is regularly verified by an independent third-party expert, whose findings are made public.

Assessment is case by case: a future commitment is not on the blacklist of practices prohibited in all circumstances, which includes product neutrality achieved through offsetting, detailed in our carbon neutrality article. The Commission FAQ, September 2026 version, confirms that the rule also applies at company level, including a pathway towards neutrality.

Who may verify the plan

The directive does not specify a verifier: according to the Commission, a private auditor or consultancy may fill the role if independent, free of conflicts of interest and environmentally competent. Frequency is not fixed; an annual review or one every 2 years is cited as good practice, and a QR code may link to the plan and findings. SBTi target validation attests to their ambition when issued; the directive additionally expects regular progress monitoring.

In France, before transposition

France, which was due to apply EmpCo by 27 September 2026, has not yet transposed it: the bill adopted by the Senate on 18 February 2026, reproducing this rule almost word for word, still awaits plenary examination in the National Assembly. Current law already penalises a misleading practice concerning "the extent of the advertiser’s commitments, particularly in environmental matters": a fine of up to €1.5 million for a company, which may rise to 10% of turnover or 80% of advertising expenditure.

The Paris judicial court relied on this legislation, without waiting for transposition, to find misleading at first instance on 23 October 2025 the way TotalEnergies presented its ambition of carbon neutrality in 2050 on its website. The EmpCo application timetable tracks legislative progress, and our article on banned environmental claims details risky wording.

5The 7 elements of a plan that stands up before an auditor

Combining the 3 texts, a credible plan brings together 7 elements. Each answers a question a statutory auditor, independent expert or state service will ultimately ask.

A starting point that can be recalculated

The plan starts from an assessment with a documented base year, scope and method, whether Bilan Carbone® or the GHG Protocol. When the scope changes through an acquisition or disposal, or an emission factor is revised, the base year is recalculated: without this, a displayed decrease may simply reflect a disposal.

Measures quantified in tCO2e

Every measure is quantified through the same operation: activity data multiplied by the difference in emission factor between the current and target situations, and the sum of measures gives the reduction volume BEGES requires. In plans we review, 2 errors recur: counting the decrease in the national electricity emission factor as an action, and adding 2 measures addressing the same consumption, insulation and a heat pump for example. Reduction measures are then ranked by their footprint contribution.

Approved resources and governance

The plan assigns each action an investment or expenditure, an owner and a date; otherwise the measure remains an intention. Management or the board then approves it, a step the CSRD report must describe. The budget need not be final: the European standard accepts a range for coming years, and public grants may cover part of it.

Assumptions, dependencies and locked-in emissions

An honest plan states what must happen outside the company for it to succeed: a reinforced electricity connection, a supplier able to deliver recycled steel or a change in carbon prices. It also identifies locked-in emissions, those a kiln, boiler or recent fleet commits until replacement, and states when they can fall.

6From assessment to plan: a quantified mid-sized industrial company case

To show the method, take a fictional company with the profile of a mid-sized industrial company subject to BEGES: a metal shelving manufacturer with 650 employees, one site in France, below the 1,000-employee threshold adopted by Omnibus for the CSRD. Its products consume no energy in use, and all calculations use emission factors from ADEME’s Base Empreinte.

Rank before quantifying

Its 2025 footprint is 17,700 tCO2e. Purchased steel accounts for 62%: 5,000 tonnes at 2,211 kgCO2e per tonne, or 11,055 tCO2e. Next come gas for kilns and heating, 9 GWh and 2,151 tCO2e including upstream emissions, electricity at 311 tCO2e and the fleet at 186 tCO2e; other sources (other purchasing, freight, travel, waste, capital goods) are fixed at 4,000 tCO2e. The mandatory BEGES scope, combustion on site and in vehicles and production of purchased electricity, or 2,168 tCO2e, accounts for only 12% of the total, with energy upstream emissions under scope 3.

The mandatory scope trap

The 3 energy measures, kiln heat recovery, a heat pump for heating and an electric fleet, remove 871 tCO2e by 2030, including 733 within the mandatory scope: -34% within that scope, a flattering result on ADEME’s platform, but only -5% of the complete footprint. The 2 purchasing measures, 40% recycled steel and 10% less steel per product, remove 3,397: the plan then reaches -24% across the complete footprint, in line with the -23% SNBC 3 sets for the country between 2025 and 2030.

What remains locked in

Even after this plan, gas kilns still emit 1,422 tCO2e a year, including 1,196 from combustion, locked in until replacement with electric kilns, which requires a more powerful electricity connection: this is the assumption and dependency the plan must explain. The electric fleet also shifts some emissions to vehicle manufacturing, counted in capital goods.

For us at Projet Celsius, the costliest mistake is building the plan solely on the mandatory scope: it displays a large percentage decrease and leaves aside 88% of emissions, those major clients ask suppliers about for their own scope 3. Our article on an industrial site’s Bilan Carbone® shows where opportunities lie in other activities.

7Where to start if your BEGES is due for renewal in 2026 or 2027

One plan, built once on the complete footprint, can feed the 3 texts, provided it is designed from the outset for the most demanding of them.

• Review the previous plan: actions carried out, reductions achieved and gaps explained, the first section the Environmental Code requires.
• Recalculate the footprint over a complete scope, including scope 3 even if it is not mandatory for you, and at a frequency suited to plan monitoring.
• Quantify each measure in tCO2e and euros, with an owner and a date, and derive the expected reduction volume.
• Set targets for the next report, 2030 and 2050, position them against SNBC 3 and have management approve the plan.
• Adapt the plan: ADEME platform sections for BEGES, section E1-1 if subject to the CSRD, a verified public page if displaying a future target.

Companies structuring their first approach can use Diag Décarbon'Action or the ACT method, launched in 2015 with ADEME, which helps build and then assess a climate strategy. If you prefer to delegate, our regulatory BEGES support covers the assessment, plan and publication.

8Key takeaways

• BEGES requires an action plan until the next report: past actions and results, actions and resources separated by emission type, expected reduction volume.
• The CSRD requires a strategy compatible with 1.5°C: 5 elements in revised ESRS E1-1, applicable to 2027 financial years, or a declaration of having no plan.
• EmpCo makes every future target displayed to consumers conditional on a detailed plan, resourced and regularly verified by an independent expert.
• The CSDDD no longer requires a plan since the Omnibus Directive of 24 February 2026.
• A quarter of BEGES plans published since 2023 omit the expected reduction volume, despite the Code requiring it: quantification measure by measure across the complete footprint makes the difference.

For each text, our mandatory BEGES guide details thresholds and timetable, our EmpCo explanation sets out the rule on future commitments, and our method for proving a claim helps formulate a climate target that stands up.

Further resources

Frequently asked questions

1Is a transition plan mandatory?

Not for all companies: it is for those subject to BEGES, more than 500 employees in mainland France and 250 overseas, which attach it to their report every 4 years. Companies subject to the CSRD describe their plan in their sustainability report, or declare they have none and state whether they intend to adopt one. EmpCo requires it for every company displaying a future environmental target in consumer communication, a rule France has not yet transposed. The European due diligence directive no longer requires one since the Omnibus Directive of February 2026.

2What must a BEGES transition plan contain?

Article R. 229-47 of the Environmental Code requires 3 elements: actions carried out since the previous report and their results, actions and resources envisaged until the next report, presented separately for direct and indirect emissions, and the overall expected reduction volume. The ministry’s official method additionally recommends medium- and long-term targets and quantifying each action’s human and financial resources.

3Can a company subject to the CSRD have no transition plan?

Yes: ESRS E1-1 does not require adoption of a plan, but description of it if one exists. Without a plan meeting the required characteristics, the company declares this and states whether it intends to adopt one, and by when. This declaration is certified alongside the rest of the sustainability report.

4Can you still display a "net zero 2050" target?

Yes, provided you can substantiate it: under EmpCo, a future target must rest on a detailed, realistic implementation plan with measurable, time-bound targets and allocated resources, regularly verified by an independent expert whose findings are public. In France, current law already penalises misleading environmental commitments, as shown by the first-instance judgment against TotalEnergies on 23 October 2025.

5Must the transition plan be validated by SBTi?

No: no legislation requires SBTi. The CSRD asks whether targets are science-based and compatible with 1.5°C, and SBTi validation is a recognised way to establish this. SBTi published version 2 of its net zero standard: under its timetable, validations using this version begin in the first quarter of 2027, version 1.3.1 remains usable until 31 January 2028 and version 2 will apply to every new submission from 1 February 2028.

6Where can you find examples of transition plans?

Plans attached to BEGES reports are public: bilans-ges.ademe.fr and ADEME’s open dataset list almost 12,000 reports published since 2015, including recent plans. Sustainability reports from companies subject to the CSRD include an E1-1 section. This article’s quantified case applies the method to a fictional mid-sized industrial company.

Ask Guillaume your questionA personal reply within 24 working hours

Send my questionor: [email protected]