Climate Transition Plan — TPT + IFRS S2 + ESRS E1-1 + SBTi V2 for Indian Listed Entities

What a climate transition plan is

A climate transition plan is a time-bound, entity-level strategic document describing how the reporting entity will transition its business model, strategy, operations, products, and value chain toward a low-emissions — and commonly net-zero — economic future. The plan combines a long-term ambition (typically net-zero by 2050, increasingly aligned to a 1.5°C trajectory), interim quantified targets across Scope 1, Scope 2, and material Scope 3 categories, the identified decarbonisation levers, the capex / opex required, governance arrangements, dependencies on policy / technology / value-chain partners, and an honest disclosure of risks and uncertainties.

The disclosure conventions across the four major frameworks — TPT (the original architecture), IFRS S2 (global investor lens), ESRS E1-1 (mandatory EU lens), and SBTi Corporate Net-Zero Standard V2 (target-validation lens) — are increasingly converging on the same conceptual content. They differ on whether having a transition plan is itself mandatory, on the materiality threshold, and on the temperature alignment basis. The post-2028 SBTi V2 will make Climate Transition Plans mandatory for all SBTi-validated companies, materially accelerating adoption across the listed-entity universe.

The four converging frameworks — at a glance

Framework	Issuer	Plan mandatory?	Temperature alignment	Status
TPT Disclosure Framework	UK Govt-convened Taskforce (concluded 31 Oct 2024); materials absorbed by IFRS Foundation Jun 2024	Voluntary good-practice framework	1.5°C ambition explicit in framework	Final Disclosure Framework 9 Oct 2023; legacy maintained by IFRS Foundation
IFRS S2 (paragraphs 13-22)	International Sustainability Standards Board (ISSB)	Not mandatory to have a plan; mandatory to disclose info about strategy to meet plan IF entity has one	Not prescribed	Issued June 2023; June 2025 transition-plan disclosure guidance
ESRS E1-1	European Commission via Delegated Reg (EU) 2023/2772	Mandatory: disclose plan OR disclose absence + timeframe to adopt	Must be compatible with 1.5°C + 2050 EU climate neutrality	In force; Revised ESRS draft (May 2026) retains E1-1 architecture
SBTi Corporate Net-Zero Standard V2	Science Based Targets initiative	Mandatory for all SBTi-validated companies	1.5°C absolute or intensity, sector-specific	V2 publication 2026; mandatory 1 Jan 2028

The TPT Disclosure Framework — the architecture everyone else builds on

The Transition Plan Taskforce (TPT) was a UK Government-convened body announced at UN COP26 in Glasgow (November 2021) and officially launched in April 2022. On 9 October 2023, it released the TPT Disclosure Framework + 13 accompanying guidance documents. The IFRS Foundation absorbed the disclosure-specific materials in June 2024, and the TPT formally concluded its work on 31 October 2024 with a Final Report.

The TPT architecture is organised around three Guiding Principles (Ambition, Action, Accountability) and five Disclosure Elements + 19 sub-elements. The Guiding Principles set the disclosure intent; the five elements prescribe what a “credible and robust” transition-plan disclosure should contain:

1. Foundation — the ambition (long-term goal, e.g. net-zero by 2050), the strategic context (business model, value chain), and how the transition plan integrates with overall strategy
2. Implementation Strategy — the levers (decarbonisation actions), the business operations changes, the products and services changes, the policies and conditions
3. Engagement Strategy — value-chain engagement, industry engagement, government / public-sector engagement
4. Metrics & Targets — quantified Scope 1, 2, 3 targets, milestones, KPIs for progress
5. Governance — board oversight, management roles, culture and skills, remuneration linkages

Although the TPT has formally concluded, the framework remains the de facto reference architecture for transition-plan disclosure globally. ESRS E1-1 implementation guidance and the IFRS Foundation’s June 2025 transition-plan disclosure guidance both draw on the TPT structure substantially.

IFRS S2 — investor-materiality lens, “disclose if you have one”

IFRS S2 Climate-related Disclosures (issued June 2023, ISSB) sits in the four-pillar TCFD-inherited architecture. The transition plan sits in the Strategy pillar (paragraphs 13-22).

Critically, IFRS S2 does not require the entity to have a transition plan. It requires disclosure of information about “the entity’s strategy to meet its transition plan” — if the entity has one. Where the entity does not have a transition plan, IFRS S2 does not require it to create one solely for the purpose of disclosure.

The IFRS Foundation published guidance on transition-plan disclosure in June 2025 (transition-plan-disclosure-s2.pdf on the IFRS site). This guidance substantially closes the structural gap with the TPT-derived architecture used in ESRS E1, while preserving the financial-materiality lens that distinguishes IFRS S2 from ESRS E1.

Industry-specific transition-plan requirements flow through IFRS S2 paragraph 32 (which incorporates SASB Industry Standards). For sectors like oil and gas, cement, steel, banking, and asset management, the SASB metrics frame the underlying targets that the transition plan delivers against.

ESRS E1-1 — mandatory, 1.5°C-aligned, EU CSRD scope

Under Commission Delegated Regulation (EU) 2023/2772, ESRS E1-1 (transition plan for climate change mitigation) is the EU’s mandatory transition-plan disclosure requirement. The disclosure objective is:

“to enable an understanding of the undertaking’s past, current, and future mitigation efforts to ensure that its strategy and business model are compatible with the transition to a sustainable economy, and with the limiting of global warming to 1.5°C in line with the Paris Agreement and with the objective of achieving climate neutrality by 2050.”

Mandatory elements of E1-1:

• The entity must disclose whether it has a transition plan, OR if not, disclose that fact and the timeframe within which it intends to adopt one
• The plan must be compatible with limiting warming to 1.5°C and achieving climate neutrality by 2050
• Disclosure of GHG emission reduction targets across Scope 1, Scope 2, and Scope 3 in absolute terms
• Disclosure of decarbonisation levers and the locked-in GHG emissions that would prevent achievement of targets
• Disclosure of capex aligned with the EU Taxonomy and the transition plan
• Disclosure of any explicit decoupling of business growth from GHG emissions

The Revised ESRS Set 1 draft (EC consultation closed 3 June 2026; see the CSRD Disclosure Framework page for the full Omnibus context) retains the E1-1 architecture but simplifies several elements. For Indian listed entities with EU subsidiaries above the post-Omnibus thresholds (>1,000 employees AND >€450M turnover), E1-1 disclosure becomes operationally relevant from FY 2027.

SBTi Corporate Net-Zero Standard V2 — mandatory transition plan from 1 Jan 2028

The Science Based Targets initiative (SBTi) is the most-cited target-validation regime globally. Its Corporate Net-Zero Standard V2 went through a second public consultation that closed on 12 December 2025. V2 will be published in 2026 and becomes mandatory for all SBTi-validated targets from 1 January 2028. Until 31 December 2027, companies may continue to validate under V1.3 + Near-Term Criteria V5.3.

V2 introduces three changes that materially affect Indian listed entities:

1. Individual Scope 1, Scope 2, and per-category Scope 3 target approaches — replacing the V1.3 consolidated framework. Entities will set separate near-term and net-zero targets per scope and (for Scope 3) per material category.
2. Third-party assurance on target progress — V2 introduces an assurance requirement to verify that companies are tracking against their validated targets.
3. Mandatory Climate Transition Plan — every V2-validated company must publish and maintain a climate transition plan as part of the validation submission.

For Indian listed entities with existing SBTi-validated targets (Reliance, Tata Group entities, Mahindra Group, Infosys, Wipro, ICICI Bank, etc.), the SBTi has stated it will provide a transition pathway aligning V1-era Scope 3 targets with V2 — preventing duplication of completed work. New SBTi target submissions from 2026 onwards should anticipate V2 framing.

How a transition plan fits SEBI BRSR + BRSR Core

SEBI does not require a separate transition-plan disclosure document as part of BRSR. However, several BRSR elements draw directly on transition-plan content:

• Principle 6 (Environment) narrative is the natural home for transition-plan narrative — environmental risk + business continuity + targets + performance
• BRSR Core Attribute on GHG Emission Intensity per Revenue (Scope 1 + Scope 2) requires the underlying methodology, baseline year, and forward trajectory — all of which are transition-plan content
• BRSR voluntary leadership indicators include targets-and-performance disclosures
• BRSR Value Chain Verification (top-1,000 listed entities, phased) draws on the engagement strategy dimension of the transition plan

The implementation pattern observed in published Indian listed-entity BRSR submissions: large entities (Reliance, TCS, Infosys, ICICI Bank, HDFC Bank, Mahindra Group, Tata Steel, Wipro, Tech Mahindra) publish a separate standalone climate / sustainability report containing the full transition plan, and the BRSR submission cross-references it. Where SBTi-validated targets exist, the SBTi commitments are the anchor for the BRSR narrative.

For BRSR Core Assurance at reasonable level (under SAE 3000 / SAE 3410), the underlying Scope 1 + Scope 2 inventory + the GHG intensity computation must reconcile with the transition-plan targets disclosed in the standalone report. Divergence between the two is a common assurance finding.

RBI Climate Risk Disclosure — the parallel Indian banking regime

The Reserve Bank of India published a Draft Disclosure Framework on Climate-related Financial Risks in February 2024, applicable to scheduled commercial banks (excluding Local Area Banks, Payments Banks, Regional Rural Banks), all Tier-IV Primary Co-operative Banks, all-India Financial Institutions, and large NBFCs. The framework draws on TCFD recommendations (now consolidated into IFRS S2) and prescribes disclosures across:

• Governance — board oversight, management responsibilities
• Strategy — climate risks and opportunities, scenario analysis, transition plan
• Risk Management — integration with overall ERM
• Metrics and Targets — financed emissions (PCAF-aligned), Scope 1 + 2 emissions, targets

The framework is in draft form and the final timeline for mandatory application is awaited. Once finalised, in-scope financial institutions will need to align with the prescribed transition-plan disclosure architecture, which materially overlaps with TPT / IFRS S2 / ESRS E1-1.

Practical implementation sequencing for Indian listed entities

For an Indian listed entity building a transition plan from scratch, the observed practical sequence:

1. GHG inventory baseline — without a credible Scope 1 + Scope 2 + material-Scope-3 inventory (GHG-Protocol-aligned, ideally SAE 3410 / ISAE 3410 reasonable-assured for BRSR Core), the transition plan has no foundation.
2. Materiality assessment — identify which sustainability matters (climate and otherwise) are material per the chosen framework. See the Materiality Assessment Walkthrough.
3. Ambition + target-setting — long-term ambition (commonly net-zero by 2050) + interim 2030 target (Paris-aligned 1.5°C, absolute or intensity); SBTi validation where in scope.
4. Levers identification — engineering + operations team identifies decarbonisation levers (energy efficiency, electrification, fuel switching, process changes, value-chain engagement, carbon removal); capex / opex profile estimated.
5. Governance + disclosure — board approval; publish plan via standalone climate report + cross-reference in BRSR Principle 6.
6. Progress tracking + refresh — annual progress disclosure + 3-year refresh of the plan itself.

The post-2028 SBTi V2 mandatory-transition-plan requirement will materially accelerate adoption across the listed-entity universe. Indian entities with UK / EU subsidiary exposure or existing SBTi commitments are running this sequence already.

Evidence the assurance practitioner expects

Across TPT, IFRS S2, ESRS E1-1, and SBTi V2, the evidence universe for an assured transition-plan disclosure converges on:

Element	Evidence typically expected
Governance	Board minutes approving the plan; board-committee climate oversight charter; remuneration policy linking executive incentives to plan KPIs
Ambition + targets	Long-term ambition resolution; interim target resolutions; SBTi validation letter (if applicable); baseline year GHG inventory + assurance report
Levers + capex	Decarbonisation-lever inventory document; capex budget aligned to levers; opex for engagement + R&D spend
Dependencies	Identified policy / technology / value-chain dependencies; mitigation actions for high-dependency risks
Engagement strategy	Value-chain engagement programme docs; industry-association memberships + alignment review; public-policy engagement statement
Monitoring	KPI definitions; milestone reporting cadence; restatement policy; latest progress report

An assured transition plan (under ISAE 3000 (Revised) or SAE 3000 (Revised) — typically as part of broader sustainability-statement assurance under CSRD limited-assurance or BRSR Core reasonable-assurance) carries materially higher signal than an unassured plan.

How Batchwise fits

For Indian listed entities preparing the GHG inventory that anchors a transition plan, Batchwise coordinates ISAE 3410 GHG verification under SAE 3410 (the Indian equivalent) through partner CA firms. For the broader BRSR Principle 6 + BRSR Core narrative that draws on transition-plan content, Batchwise coordinates BRSR Core Assurance at reasonable-assurance level.

Where the entity is also in scope for CSRD (via a large EU subsidiary or third-country group thresholds — see the CSRD Disclosure Framework page), the ESRS E1-1 transition-plan disclosure is a separate workstream typically delivered by a different EU-side assurance provider, but the underlying GHG inventory + governance documentation is shared. The data infrastructure that supports BRSR Core also supports E1-1.

See also: TCFD Disclosure Framework for the predecessor four-pillar architecture; GHG emission intensity per revenue for the BRSR Core attribute that anchors transition-plan numerics; SBTi glossary entry for the validation regime that will make plans mandatory from 2028.