Simplification · DD-11

Adopt a transition plan for climate change mitigation, including implementing actions planned and taken, aimed at aligning the business model and strategy with the 1.5 degC pathway and EU climate-neutrality targets

Addressee Companies referred to in Art. 2(1)(a)-(c) and Art. 2(2)(a)-(c) of Directive (EU) 2024/1760Act COM(2025) 81, 2025/0045 (COD)Article Art. 4(10), replacing Art. 22(1) of Directive (EU) 2024/1760Class Businesses

What changes

Companies required to adopt a transition plan keep that duty, but the operational bar drops from 'putting it into effect' to including planned/taken implementing actions on a best-efforts basis.

Prior rule vs new rule

Prior rule

Obligation

the requirement to put into effect the transition plan for climate change mitigation should be replaced by a clarification that the obligation of companies to adopt a transition plan includes outlining implementing actions, planned and taken.

New rule

Obligation

Adopt a transition plan for climate change mitigation, including implementing actions planned and taken, aimed at aligning the business model and strategy with the 1.5 degC pathway and EU climate-neutrality targets

Who is affected

Addressee

Companies referred to in Art. 2(1)(a)-(c) and Art. 2(2)(a)-(c) of Directive (EU) 2024/1760

Class

Businesses

Sectors

No sector named — applies by size or activity

Applies

Once transposed by Member States (transposition due within 12 months of this Directive's entry into force)

Burden drivers

No burden drivers recorded on this provision.

Source text

Verbatim

Member States shall ensure that companies referred to in Article 2(1), points (a), (b) and (c), and Article 2(2), points (a), (b) and (c), adopt a transition plan for climate change mitigation, including implementing actions, which aim to ensure, through best efforts, that the business model and strategy of the company 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 the objective of achieving climate neutrality as established in Regulation (EU) 2021/1119, including its intermediate and 2050 climate neutrality targets, and where relevant, the exposure of the company to coal-, oil- and gas-related activities.

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