ESRS E1: what the revised CSRD climate standard asks of building data

On 3 July 2026, ESRS E1 went from 9 to 11 disclosure requirements^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. Most of them are calculated from the meters in your buildings.

Energy consumption, greenhouse gas emissions, risks linked to climate change: every company in scope will publish these figures in its sustainability report. An auditor will check them, even though nobody has made them reliable at the source. We read each requirement from the point of view of a commercial building portfolio, then follow the data all the way down to the meter.

E1 seen from a real estate portfolio: definition, sustainability matters and companies in scope after the Omnibus

What ESRS E1 covers within the CSRD

E1 is the climate standard of the corporate sustainability reporting directive. It requires the company in scope to disclose its climate-related impacts, risks and opportunities across three topics: mitigation, adaptation to climate change, and energy. These standards were adopted by Delegated Regulation (EU) 2023/2772, based on EFRAG's technical work^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}.

For an owner or occupier of offices, this ESRS standard reads first and foremost as a request for data. CSRD reporting calls for kWh, tCO2e and resources committed, all of which the CSRD wants to be traceable. These figures come out of the boiler rooms and meters of a portfolio committed to sustainable real estate, rarely out of a communications spreadsheet.

Transparency and the 1.5 °C pathway: what the CSRD is trying to achieve

The CSRD aims at a precise result: making climate information that used to be self-declared comparable and verifiable. Before it, each report chose its own boundary and indicators. Sustainability matters are now measured with the same rules from one company to the next.

The common benchmark remains the Paris Agreement, which aims to limit warming to 1.5 °C^{[2][2]RegulationUNFCCC, “Paris Agreement”, goal of limiting warming to 1.5 °CSee in sources ↓}. Every published target is compared with this transition pathway.

Mitigate, adapt, manage energy: the three topics of E1

Mitigation means reducing the portfolio's greenhouse gas emissions: less gas burned in the boiler room, better-controlled refrigerants, a low-carbon pathway for each asset. The second topic asks for buildings to be adapted to climate hazards, from heat waves to heavy rainfall. The third covers the energy consumed, measured and then broken down by source. Every action reported is attached to one of these three topics.

E1 among the 12 ESRS standards and sustainability matters

E1 belongs to a set of 12 standards^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}. Two are cross-cutting: the first sets out the principles, the second the general disclosures. Five cover the environment (E1 to E5): climate, pollution, water and marine resources, biodiversity, resource use and circular economy. Four deal with workers, communities and end users (S1 to S4), and the last one with governance (G1). For a commercial building portfolio, E1 concentrates most of the quantified sustainability matters.

Double materiality: the burden of proof that keeps climate in the sustainability report

E1 only applies if climate comes out as material in the double materiality assessment. That assessment combines two perspectives. The first concerns the company's environmental impact, as an actual or potential negative impact. The second concerns the financial risks and opportunities linked to climate. Leaving climate out of the sustainability report requires a detailed justification^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}.

The burden of proof therefore lies with whoever excludes it. An owner of gas-heated offices who left climate out would have a hard time defending that choice in front of an auditor.

The weight of buildings in a company's climate reporting

Even in an industrial or services company, offices, warehouses and workshops weigh heavily in climate reporting. Heating, cooling and ventilation feed directly into direct emissions and electricity-related emissions. CSRD for buildings then becomes a decisive topic for a real estate department, because the management of the portfolio supplies a major share of the environmental impact reported.

Did you know? In the European Union, buildings account for 40% of energy consumption and 36% of energy-related greenhouse gas emissions^{[3][3]RegulationEuropean Parliament and Council, “Directive (EU) 2024/1275 on the energy performance of buildings (EPBD)”See in sources ↓}.

Applied to your portfolio, these orders of magnitude mean that a credible climate and ESG transformation goes through your boiler rooms before your slide decks.

Application thresholds after the Omnibus I directive

The Omnibus I directive narrowed the scope of the corporate sustainability reporting directive. Companies remain in scope if they have more than 1,000 employees and €450 million in net turnover^{[4][4]RegulationEUR-Lex, “Directive (EU) 2026/470 of 24 February 2026” (Omnibus I), CSRD application thresholdsSee in sources ↓}.

Being an ETI (a French mid-tier company), a large company or an SME no longer settles the question. Only crossing these two thresholds counts. Many mid-sized property companies fall out of the mandatory scope. That does not take them out of the data requests, as we will see below.

Reporting timeline: what the “stop-the-clock” postponement has shifted

Directive (EU) 2025/794, known as “stop-the-clock”, postponed waves 2 and 3 by two years^{[5][5]RegulationEuropean Parliament and Council, “Directive (EU) 2025/794”, postponement of waves 2 and 3 known as “stop-the-clock”See in sources ↓}. The first wave, already subject to the rules, keeps reporting every year.

For the others, this delay is no reprieve. A few months are rarely enough to make the meter history of a portfolio reliable. Defensible CSRD reporting is prepared with two or three winters of clean data.

Property company, large occupier, property manager: who discloses what on the same building?

On the same building, several parties publish figures that overlap. The property company in scope reports its assets under CSRD for property companies, including the tenants' consumption that falls within its value chain. The large occupier also publishes its own consumption, metered on its side of the lease.

The property manager, for its part, publishes nothing in its own name for the asset: it works on behalf of the owner. In CSRD for real estate, the same kWh therefore appears in two separate CSRD reports.

ETIs and SMEs out of scope: the data request that comes through the value chain

An ETI, large company or SME out of scope does not escape the questions. A tenant in scope will ask its landlord for the consumption of the common areas. A landlord in scope will ask its tenant for its private-area consumption. These requests travel up the value chain the way a supplier questionnaire travels up a supply chain. Even the smallest user of an office floor becomes a data supplier, especially when its lease includes a green lease annex (annexe environnementale).

E1 revised in 2026: what changes, and each disclosure requirement read from a real estate portfolio

The delegated act of 3 July 2026: from 9 to 11 disclosure requirements

On 3 July 2026, the Commission adopted delegated act C(2026) 5010, which revises E1^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. The 2023 version had nine requirements. The revised text goes from 9 to 11 disclosure requirements^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. The Commission presents the revision as a simplification. Yet the two new requirements deal with risks and their impacts. For a company that already reports, this news means re-reading the ESRS standard requirement by requirement. Your regulatory watch starts from the published text, never from a summary.

Mapping of E1 requirements between the 2023 version and the revised version

The renumbering blurs the landmarks. The former E1-5 on energy becomes E1-7, and the former E1-6 on GHG becomes E1-8. The table below puts each requirement opposite its former number, with its consequence for a commercial building portfolio^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}.

In your portfolio, look at three rows first. The transition plan becomes defensible even when it deviates, provided the reason is documented. The GHG boundary can move a building from one category to another depending on the lease. The two added requirements call for an asset-by-asset analysis that few real estate departments have produced yet. The other rows are renumbered with no change in substance. One thing does not move from one version to the next: everything is calculated from a clean meter history, a resource scarcer than people think.

Climate risks, scenario analysis and resilience: the two added requirements

The 2023 version dealt with these topics in a scattered way, in support of the general requirements^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}. The revised text turns them into two stand-alone requirements^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. Our reading: the Commission is after comparability. An investor wants to read the climate risk of a portfolio over the short, medium and long term, backed by explicit scenarios. Every exposure factor must be named. Resilience becomes a result to be demonstrated, no longer a statement of intent.

Transition plan: a deviation from the 1.5 °C pathway can now be justified

The revised text accepts that a climate transition plan may deviate from the Paris Agreement pathway, as long as the deviation is explained^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. For a commercial building portfolio, the news cuts both ways. A building whose renovation is waiting for the end of the lease can stay above the curve. You still have to show its actual consumption and the decision that sets the date of the works. Without solid data, the explanation will not hold.

Emissions boundary: financial control by default and alternative approaches

The GHG Protocol distinguishes three consolidation boundaries: financial control, operational control and equity share^{[7][7]Studies and reportsGHG Protocol, “Corporate Accounting and Reporting Standard”See in sources ↓}. The revised text adopts financial control by default^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. Alternative approaches remain possible if they are justified. Under financial control, a landlord in principle keeps its buildings let under operating leases in its scopes 1 and 2^{[7][7]Studies and reportsGHG Protocol, “Corporate Accounting and Reporting Standard”See in sources ↓}. The tenant then finds them in category 8. Changing approach in the middle of a series breaks any comparison.

Entry into application of the revised text: points still to be confirmed

A delegated act only enters into force after the objection period open to the European Parliament and the Council^{[8][8]RegulationEuropean Union, “Treaty on the Functioning of the European Union”, Article 290, delegated actsSee in sources ↓}. The text adopted on 3 July 2026 provides for application to financial years starting on or after 1 January 2027, with possible early application from financial year 2026 for companies already in scope^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. Its publication in the Official Journal still needs to be monitored before anything is used in a report. Our regulatory-watch rule: prepare the data on the revised grid, report on the grid in force.

E1-1: transition plan for climate change mitigation

From here on, the numbering used is that of the revised text. E1-1 asks for the reduction pathway and the levers that support it. For a portfolio, this translates into a pathway per asset and renovation CAPEX phased over the short, medium and long term. The economic activities covered must remain consistent with this low-carbon path. Property companies often rely on CRREM for the transition plan, which provides decarbonization curves by asset type.

E1-2: physical and transition climate risks for a commercial building portfolio

In an office building, the most tangible physical risk is heat. Heat waves drive up cooling demand and degrade workers' comfort, and even their health. The transition risk lies in dependency on gas or heating oil. Each location has its own exposure: flooding, drought, pressure on the water used by cooling towers. Climate risk is therefore assessed asset by asset, over the short, medium and long term.

E1-3: resilience of the portfolio to climate risks

The company must demonstrate that its assets absorb hazards without losing function. During a heat wave, a resilient building holds its setpoints without an oversized chiller. A vulnerability study is not enough to prove it. The trend logs of the BMS (building management system) complete the demonstration: indoor temperatures recorded during the last episode, hours outside setpoint, power drawn.

E1-4: mitigation and adaptation policies (formerly E1-2)

E1-4 covers written policies: what the company commits to doing in terms of climate change mitigation and adaptation. A technical management charter for the portfolio, an energy purchasing policy or a setpoint rule belong here. The distinction matters. A policy announces an intention; an action produces a measurable effect. The auditor will not confuse the two.

E1-5: actions and resources committed (formerly E1-3)

An action is described with the resources committed and its measured effect. At Valeo, HVAC control delivered −28.6% HVAC consumption, measured according to the IPMVP protocol^{[9][9]Field feedbackFoobot, Valeo case study, HVAC consumption measured according to the IPMVP protocolSee in sources ↓}. That is the expected format: one action, one measurement method, one verifiable result. An action plan without measurement remains a list of intentions. The auditor will read it as such, however experienced the team that wrote it.

E1-6: short-, medium- and long-term reduction targets (formerly E1-4)

The Décret tertiaire (France's tertiary decree on energy savings in commercial buildings) requires -40% final energy consumption by 2030 compared with a reference year^{[10][10]RegulationLégifrance, “Decree No. 2019-771” (Décret tertiaire), obligations to reduce final energy consumption in commercial buildingsSee in sources ↓}. E1-6 deals with GHG, and the two targets must not be confused. A building that switches from gas to a district heating network can cut its emissions without cutting its kWh. Set short-, medium- and long-term targets on both metrics, each with its own baseline.

E1-7: energy consumption and energy mix (formerly E1-5)

For CSRD energy consumption, the expected datapoints are the following, subject to their being retained in the delegated act^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}:

• total energy consumption, in MWh;
• share from fossil sources, broken down by nature and type of source;
• share from nuclear sources;
• renewable share, produced on site or purchased;
• energy intensity relative to net turnover.

In a building, the total comes from the main meters and the invoices. The breakdown by source depends on the contract and on the supplier's mix. End users' consumption, on the private-area side, comes in through the tenant. A per-square-metre ratio can still be used instead of a reading, provided this is disclosed.

E1-8: gross scopes 1, 2 and 3 greenhouse gas emissions (formerly E1-6)

E1-8 asks for gross greenhouse gas emissions, scope by scope, then their total. The calculation follows the GHG Protocol^{[7][7]Studies and reportsGHG Protocol, “Corporate Accounting and Reporting Standard”See in sources ↓}. For a commercial building portfolio, scopes 1 and 2 are rebuilt from fuels, refrigerants and purchased energy. Scope 3 depends mainly on the lease. The next section details each scope from the building's point of view.

E1-9: GHG removals and carbon credits

This requirement would correspond to the former E1-7, subject to confirmation in the delegated act. It covers removals and purchased carbon credits. For a commercial building portfolio, the topic remains marginal. Remember one rule: a purchased credit does not reduce the gross carbon footprint reported. It is disclosed separately.

E1-10: internal carbon pricing

An internal carbon price is used to decide between two CAPEX options. Replacing an end-of-life gas boiler with a heat pump costs more to buy. Valued at that price, the tonnes avoided can reverse the decision. E1-10 requires this price and its use to be disclosed. A renovation opportunity is easier to defend once it is quantified.

E1-11: financial effects of climate risks and opportunities

E1-11 translates climate impacts into euros. For a portfolio, the economic value of the asset is at stake: discount on an energy-hungry building at resale, upgrade cost, higher vacancy. On the opportunity side, a measured drop in service charges supports the rent. Climate risk becomes a financial line item. Climate and ESG transformation then leaves the CSR report and enters the business plan.

GHG emissions of a real estate portfolio: methods, data holders and the weak link of the meters

Scope 1: boiler combustion and refrigerant leaks

A building's scope 1 comes down to two items. Combustion is calculated by multiplying the kWh of gas or heating oil by an emission factor. Refrigerant leaks follow another method: mass recharged multiplied by the refrigerant's global warming potential. These fluorinated greenhouse gases fall under Regulation (EU) 2024/573^{[11][11]RegulationEuropean Parliament and Council, “Regulation (EU) 2024/573 on fluorinated greenhouse gases”See in sources ↓}. In an air-conditioned portfolio, this second item is far from negligible.

Scope 2: electricity, district heating and district cooling

Scope 2 covers purchased electricity, heat and cooling. The GHG Protocol requires two calculations in parallel^{[12][12]Studies and reportsGHG Protocol, “Scope 2 Guidance”See in sources ↓}. The location-based approach applies the average emission factor of the electricity grid. The market-based approach uses the contract's factor, including guarantees of origin. For an urban district heating network, the network's own factor applies. Publish both: the gap between them tells the story of your purchasing policy.

Real estate scope 3: leased assets and the value chain

Real estate scope 3 plays out mainly in two of the GHG Protocol's 15 categories^{[13][13]Studies and reportsGHG Protocol, “Corporate Value Chain (Scope 3) Standard”See in sources ↓}. Category 13 covers downstream leased assets, on the landlord's side. Category 8 covers upstream leased assets, on the tenant's side. Depending on the consolidation approach, these are often the same kWh, counted on either side of the lease. The rest of the value chain also weighs in: renovation materials, circular economy of equipment, the maintenance contractors' supply chain. For a property company, this scope can concentrate most of the carbon footprint.

GHG Protocol, Bilan Carbone® and regulatory BEGES: three frameworks to fit together

The GHG Protocol sets the international framework for greenhouse gas emissions accounting. The Bilan Carbone, a French method born at ADEME (the French agency for ecological transition), applies its own rules and its own database of factors. The regulatory BEGES (France's mandatory greenhouse gas emissions report) derives from Article L.229-25 of the French Environment Code (code de l'environnement) and from Decree No. 2022-982^{[14][14]RegulationLégifrance, “Article L.229-25 of the French Environment Code and Decree No. 2022-982”, regulatory greenhouse gas emissions report (BEGES)See in sources ↓}. None of the three is E1, and a compliant BEGES does not cover everything. E1 expects the significant scope 3 categories, a boundary aligned with the financial statements, and external assurance.

Measured or estimated data: what each source is worth in the published figure

Not all data carries the same weight. Time-stamped metering tied to an end use is worth more than an invoice. An invoice is worth more than a per-square-metre ratio. Estimates remain acceptable in CSRD reporting, provided they are flagged along with their method. The classic trap: an annual gas invoice split pro rata to floor areas, presented as a measurement. The larger the estimated share of your emissions, the more fragile the assurance becomes.

If you cannot answer, the problem lies somewhere between the requirement and the meter. What remains is to find where the data gets lost.

The data chain, from the disclosure requirement to the meter

A disclosure requirement never reads a meter directly. In between, the data passes through several hands, and any of them can lose it. The following diagram lays out this chain on a commercial site, in four columns: the requirement, the physical data, its holder and the break point.

Now read the diagram from right to left, as the auditor will. Each break point in the fourth column goes back up to a published requirement. A gap in the history of a main meter weakens E1-7. An incomplete refrigerant log understates the scope 1 of E1-8. BMS access that was never written into a contract blocks sub-metering, and with it the measurement of E1-5 actions and the tracking of E1-6 targets. The implementation of CSRD reporting starts with these breaks, before any choice of software. The nature and type of each source are documented before the slightest calculation.

Owner, tenant, operator, maintenance contractor: who actually holds the data

The property company holds the main meters and the energy contracts for the common areas. The tenant holds its private-area invoices. The operator runs the BMS and its trend logs. The refrigeration maintenance contractor keeps the recharge log. No party has the full picture. Within the value chain of a single building, the reporting company depends on contracts it has sometimes never re-read. Data that nobody has written into a contract in practice belongs to nobody.

Collecting building by building at a property company: common areas and private areas

Under CSRD for property companies, collection is done site by site. Common areas are metered by the landlord, on its own meters. Private areas come in through the tenant, the only one who sees its invoices. To obtain end users' consumption, the green lease annex remains the strongest lever. Without it, the property company estimates.

Large multi-site occupier: consolidating heterogeneous leases and sites

A large occupier consolidates sites that look nothing alike. A properly sub-metered owner-occupied head office sits alongside leased branches with no access to the meters. A warehouse sometimes has only an annual reading. In CSRD for real estate, the company must show the actual level of measurement for each site. Mixing readings and ratios without saying so makes the series unverifiable.

One collection for three reports: ESRS E1, Décret tertiaire and GRESB

The same meter consumption feeds three filings. The Décret tertiaire requires an annual declaration on OPERAT^{[15][15]RegulationLégifrance, “Ministerial order (arrêté) of 10 April 2020”, reporting of energy consumption on the OPERAT platformSee in sources ↓}, the French government's energy-consumption reporting platform. GRESB asks the funds and property companies that respond to it for consumption per asset. E1 uses the same kWh. A single reliable collection is enough for all three, provided the same boundary and the same reference year are kept. Implementation hinges on consistency between the three reports.

What limited assurance will check in your energy figures

Knowing who holds the data does not tell you whether it will hold up. Sustainability information is certified by a statutory auditor or an independent third-party body (OTI)^{[16][16]RegulationLégifrance, “Ordinance No. 2023-1142”, publication and certification of sustainability informationSee in sources ↓}. Under limited assurance, the auditor does not recalculate everything. They pick a published figure and follow the trail back: consolidation file, export, reading, meter. If a link is missing, the figure becomes unverifiable information. The report stands or falls on this traceability.

Unidentified meters, gaps in history and duplicates

In the field, the chain breaks at the very first link. We have come across portfolios with 500 meters where nobody knows which ones are reliable. They include meters without labels and gaps in history after every supervision outage. They also include duplicates counted twice in the total (the BMS handed over with no snags, whose metering points nobody tested). Data of this kind does not survive the auditor.

No HVAC sub-metering: consumption that cannot be broken down by end use

Without sub-metering, heating, air conditioning and lighting merge into a single main meter. An action on the AHU (air handling unit) can then no longer be isolated, even though E1-5 requires its effect to be described. The CSRD energy consumption of E1-7 also benefits from being broken down by end use. Using the metering points already present in the BMS can close the gap without any works.

Refrigerants: the recharge log, the blind spot of scope 1

Regulation (EU) 2024/573 requires leak checks and traceability of recharges^{[11][11]RegulationEuropean Parliament and Council, “Regulation (EU) 2024/573 on fluorinated greenhouse gases”See in sources ↓}. This log is the only reliable source on leaks. An untracked recharge is an unreported leak. It is missing from direct emissions, even though these fluorinated greenhouse gases weigh heavily. Ask the maintenance contractor for the log of every chiller before closing scope 1.

HDD weather correction: separating the weather effect from the effect of actions

A mild winter brings heating consumption down without any action at all. Reporting this drop as a reduction is indefensible. HDD weather correction brings each year back to a reference climate, based on heating degree days (HDD, called DJU in France). The goal: compare consumption at equal weather.

This correction makes the series readable. It does not yet tell you which action produced the drop.

IPMVP protocol: proving that a reported reduction comes from an action

The IPMVP protocol, for International Performance Measurement and Verification Protocol, is published by the Efficiency Valuation Organization^{[17][17]Studies and reportsEVO (Efficiency Valuation Organization), “International Performance Measurement and Verification Protocol (IPMVP)”See in sources ↓}. Its method rests on an adjusted baseline: the consumption the building would have had without the action, recalculated with actual weather and occupancy. The difference with measured consumption is the saving. A third party can redo the calculation, and that is what turns an action plan into a reportable reduction.

Implementing E1 on a real estate portfolio and checking that your data will withstand assurance

Step 1: confirm the materiality of climate and the consolidation boundary

Implementation starts with two decisions that condition everything else. The first is to document why climate is material for your portfolio, using the double materiality argument set out above. The second is to fix the consolidation boundary, building by building, under financial or operational control. A wrongly attached asset distorts every quantified matter in the standard. This choice then guides collection.

Step 2: map energy and emission sources building by building

For each site, list the nature and type of energy source: electricity, gas, heating oil, district heating, district cooling. Add the direct emission sources that invoices do not show, starting with chillers and their refrigerants. Finally, note who holds each piece of data. This map quickly reveals the buildings where nobody can answer.

Step 3: make meters and histories reliable before collection

Make the data reliable before collecting it, never the other way round. A collection launched on doubtful meters produces a clean spreadsheet and false figures that nobody dares reopen afterwards. First check that each key meter is identified, communicates and logs its history without gaps. Fix the duplicates and the drifts. The data that comes out of this step is the data the auditor will be able to trace.

Step 4: calculate, consolidate and link each figure to its source

The calculation of greenhouse gas emissions follows the principles of the GHG Protocol^{[7][7]Studies and reportsGHG Protocol, “Corporate Accounting and Reporting Standard”See in sources ↓}. An existing Bilan Carbone can feed into it, provided its boundary is identical. The method rule fits in one line: each consolidated figure points to a file, a meter, an invoice or a written assumption. A total with no link to its source will not pass assurance.

Step 5: document the action plan and the audit trail

Finally, document the action plan: which measures, on which assets, with which resources and what expected effect. Keep the audit trail that links each published figure to its source and its calculation method. The disclosure requirements on actions and targets rely on this file. Without it, a plan remains an intention.

Eight questions to ask your operator before the E1 collection

Before launching collection, a frank conversation with your operator teaches you more than a reporting review carried out after the fact. The eight questions below are the ones we ask first on a portfolio. They deal with meter identification, continuity of trend logs, HVAC sub-metering and refrigerants. They also cover private-area consumption, district networks, access to the BMS and weather correction.

Answer without rounding up, “I don't know” included: it is often the most revealing answer. The tool does not give you a score. It indicates, in the conditional, which E1 disclosures would be hard to defend in front of the auditor.

Reading your result: what each negative answer weakens in the report

The diagnostic shows requirements rather than a score, because each negative answer points to a specific requirement. An unidentified meter or a trend log with gaps weakens E1-7, energy consumption, first. An incomplete refrigerant log affects E1-8 on the scope 1 side. Missing private-area consumption hits it on the category 13 side.

Missing HVAC sub-metering or undocumented HDD weaken E1-5: the effect of an action can no longer be isolated. A single answer can thus weaken several disclosure requirements.

Where to start when several answers are negative?

With access to the data, always. If your operation and maintenance contract does not provide for BMS trend logs to be passed on, no tool will make up for it. Next come the main meters, then HVAC sub-metering and the refrigerant log. The action plan is written in that order. The reporting software you are shown first comes last.

What Foobot brings upstream of E1 reporting

BMS advisory: making meters reliable before the auditor tests them

Our BMS advisory starts where the auditor will end: at the meter. On a data-reliability assignment, we track down disconnections, data gaps, duplicates and invisible drifts. These faults distort an annual consumption figure without triggering a single alarm. We also check that manual overrides do not inflate consumption without anyone knowing. The result is data that goes into CSRD reporting with no reservations from the operator.

AI Control and AI Optimal Start: measured HVAC reductions for the transition plan

Once the foundation is reliable, if the building is genuinely complex, AI Control regulates the HVAC every 15 minutes, 24/7. It relies on a digital twin trained on the building's trend logs. At Valeo, the reduction measured according to the IPMVP protocol reaches -28.6% of HVAC consumption^{[9][9]Field feedbackFoobot, Valeo case study, HVAC consumption measured according to the IPMVP protocolSee in sources ↓}.

AI Optimal Start recalculates the start-up time of each zone every day. These documented reductions feed the transition plan with a defensible low-carbon pathway.

Integration with the existing BMS: BACnet, LON and API, with no added hardware

We read the trend logs where they already exist: on the BMS, via BACnet or LonWorks (often shortened to LON). The connection goes through a multi-protocol controller or through the supervision system, with no added hardware. Our documented public API then passes the qualified data on to the company's reporting tool. One prerequisite remains, the one from question 7 of the diagnostic: access to the BMS must be written into the contract. Without it, implementation stalls.

What Foobot does not do: no sustainability report, no carbon footprint

We do not write your sustainability report and we do not calculate your Bilan Carbone. These deliverables belong to your CSR department, your consultancy or your reporting tool. Our place is upstream: making reliable the meters on which your carbon footprint depends, then documenting the reductions achieved on the HVAC.

Before writing E1, open up your meters

The figures E1 asks you to publish are not born in a spreadsheet. They come out of your meters, your invoices and your refrigerant logs, building by building. The auditor will walk this path backwards, from the report down to the meter. They will stop at the first link that no document connects to the next one. A company that writes before making its data reliable publishes climate figures it will not be able to defend. So start with the data: identify, log, correct, and only then consolidate. The same effort serves the Décret tertiaire, GRESB and every report still to come. Have your meters made reliable before your next collection campaign.

one reliable collection for every report

FAQ - ESRS E1

Is the Bilan Carbone® mandatory under the CSRD?

No. Bilan Carbone® is a registered French method. The directive imposes a result: disclosing emissions by scope, calculated according to principles aligned with the GHG Protocol^{[7][7]Studies and reportsGHG Protocol, “Corporate Accounting and Reporting Standard”See in sources ↓}. A Bilan Carbone can feed into this calculation if it covers the same boundary.

Is an audit of the Bilan Carbone® mandatory under the CSRD?

Not as such. What is verified is the information published in the report, emissions included. A statutory auditor or an OTI checks it under limited assurance^{[16][16]RegulationLégifrance, “Ordinance No. 2023-1142”, publication and certification of sustainability informationSee in sources ↓}, tracing it back to the source data.

What does a CSRD-compatible Bilan Carbone® cost?

No serious price range holds without looking at the portfolio. The cost depends on the number of sites, the weight of scope 3 and, above all, the quality of the available data. Meters that first need to be made reliable lengthen the assignment considerably.

Is a carbon footprint assessment mandatory under the CSRD?

The method is not; the result is. As soon as climate is material, E1 requires gross scopes 1, 2 and 3 greenhouse gas emissions to be disclosed^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. The calculation must remain traceable.

What is the difference between an ADEME carbon footprint and the CSRD requirements?

An ADEME-style carbon footprint (Bilan Carbone) answers the question “how much do we emit?”. The E1 disclosure requirements ask for more: separate scopes, targets, a transition plan and the financial effects of climate risks^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. The former often provides the tooling for the latter.

Why is EFRAG at the heart of the CSRD and the ESRS standards?

The corporate sustainability reporting directive entrusts it with the technical development of the standards, which the Commission then adopts as delegated acts^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}. EFRAG drafts. The Commission decides, as the revision of 3 July 2026 showed^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}.

What is the list of the 12 ESRS standards?

Two cross-cutting standards, numbered 1 and 2. Five environmental: climate, pollution, water and marine resources, biodiversity, circular economy. Four social: own workforce, workers in the value chain, affected communities, consumers and end users. One on governance^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}.

What is the difference between the CSRD and the ESRS?

The CSRD sets the obligation: who reports, when and with what verification. The standards, adopted by delegated regulation, set the content: indicators, methods, level of detail^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}. The former has to be transposed into national law; the latter apply directly.

How many ESRS standards is the CSRD based on?

On twelve standards in the initial set: two cross-cutting and ten topical, covering environmental, social and governance sustainability matters^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}. For a real estate portfolio, E1 concentrates most of the figures that come out of the meters.

What is the only ESRS mandatory for all companies?

Cross-cutting standard No. 2, devoted to general disclosures. Every company in scope publishes it, whatever the outcome of its double materiality assessment^{[1][1]RegulationEuropean Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUSee in sources ↓}. Topical standards, E1 included, only apply if the matter is material.

From when must emissions be disclosed under the CSRD?

Directive (EU) 2025/794, known as “stop-the-clock”, postponed waves 2 and 3 by two years^{[5][5]RegulationEuropean Parliament and Council, “Directive (EU) 2025/794”, postponement of waves 2 and 3 known as “stop-the-clock”See in sources ↓}. For a company still in scope after the Omnibus, the first report depends on its wave and on national transposition.

Are estimated emissions accepted in the CSRD report?

Yes, provided they are documented: method, assumptions, estimated share. The auditor mainly checks that the estimate is reproducible. In CSRD reporting, the challenge remains to reduce the estimated share wherever meter data already exists.

Which companies are subject to the ESRS after the Omnibus directive?

Those with more than 1,000 employees and €450 million in net turnover^{[4][4]RegulationEUR-Lex, “Directive (EU) 2026/470 of 24 February 2026” (Omnibus I), CSRD application thresholdsSee in sources ↓}. An ETI, large company or SME below these thresholds falls outside the direct scope. Yet it still receives data requests from counterparties that are in scope.

What are Disclosure Requirements?

It is the English name of the “exigences de publication”: each numbered block, from E1-1 to E1-11, that says what to disclose. The revised version of E1 has 11 of them, compared with 9 in 2023^{[6][6]RegulationEuropean Commission, “Delegated act C(2026) 5010”, revision of the E1 standardSee in sources ↓}. Each then breaks down into datapoints.

What is the objective of the ESRS E1 standard?

To make the company disclose what climate costs it and what it costs the climate: emissions, pathway, risks, financial effects. The whole is read in the light of the Paris Agreement^{[2][2]RegulationUNFCCC, “Paris Agreement”, goal of limiting warming to 1.5 °CSee in sources ↓} and of the transition plan the company has set out.

SourcesSources and references

Texts and frameworks cited in the article, in order of first citation.

Regulation12

1. [1]European Commission, “Commission Delegated Regulation (EU) 2023/2772”, European Sustainability Reporting Standards, first set, OJEUJuly 2023↑ 1 2 3 4 5 6 7 8 9 10 11
2. [2]UNFCCC, “Paris Agreement”, goal of limiting warming to 1.5 °CDecember 2015↑ 1 2
3. [3]European Parliament and Council, “Directive (EU) 2024/1275 on the energy performance of buildings (EPBD)”April 2024↑
4. [4]EUR-Lex, “Directive (EU) 2026/470 of 24 February 2026” (Omnibus I), CSRD application thresholds24 February 2026↑ 1 2

Show the other 8: [5] to [16]

1. [5]European Parliament and Council, “Directive (EU) 2025/794”, postponement of waves 2 and 3 known as “stop-the-clock”April 2025↑ 1 2
2. [6]European Commission, “Delegated act C(2026) 5010”, revision of the E1 standard3 July 2026↑ 1 2 3 4 5 6 7 8 9 10 11 12 13
3. [8]European Union, “Treaty on the Functioning of the European Union”, Article 290, delegated acts↑
4. [10]Légifrance, “Decree No. 2019-771” (Décret tertiaire), obligations to reduce final energy consumption in commercial buildingsJuly 2019↑
5. [11]European Parliament and Council, “Regulation (EU) 2024/573 on fluorinated greenhouse gases”February 2024↑ 1 2
6. [14]Légifrance, “Article L.229-25 of the French Environment Code and Decree No. 2022-982”, regulatory greenhouse gas emissions report (BEGES)July 2022↑
7. [15]Légifrance, “Ministerial order (arrêté) of 10 April 2020”, reporting of energy consumption on the OPERAT platformApril 2020↑
8. [16]Légifrance, “Ordinance No. 2023-1142”, publication and certification of sustainability informationDecember 2023↑ 1 2

Studies and reports4

1. [7]GHG Protocol, “Corporate Accounting and Reporting Standard”↑ 1 2 3 4 5
2. [12]GHG Protocol, “Scope 2 Guidance”↑
3. [13]GHG Protocol, “Corporate Value Chain (Scope 3) Standard”↑
4. [17]EVO (Efficiency Valuation Organization), “International Performance Measurement and Verification Protocol (IPMVP)”↑

Field feedback1

1. [9]Foobot, Valeo case study, HVAC consumption measured according to the IPMVP protocol↑ 1 2