The short version: In the 2023 ESRS, E1-6 is the gross Scope 1, 2 and 3 GHG emissions disclosure. In the revised ESRS the Commission adopted on 3 July 2026, that disclosure is renamed E1-8, and the E1-6 label now covers GHG reduction targets. The revised standards are mandatory from FY2027. You can opt in for FY2026.
That means "E1-6" now means two different things depending on the version you're reading. This guide sorts out which rules apply to you, what each version requires, and what to change in your emissions data system before FY2027.
The renumbering at a glance
The revised ESRS E1 goes from nine disclosure requirements to eleven. Two labels now point to different topics.
| Topic | ESRS 2023 | Revised ESRS (2026) |
|---|---|---|
| Transition plan for climate change mitigation | E1-1 | E1-1 |
| Climate-related risks and scenario analysis | ESRS 2 SBM-3 / IRO-1 | E1-2 |
| Climate resilience | ESRS 2 SBM-3 | E1-3 |
| Policies | E1-2 | E1-4 |
| Actions and resources | E1-3 | E1-5 |
| GHG reduction targets | E1-4 | E1-6 |
| Energy consumption and mix | E1-5 | E1-7 |
| Gross Scope 1, 2, 3 GHG emissions | E1-6 | E1-8 |
| GHG removals and carbon credits | E1-7 | E1-9 |
| Internal carbon pricing | E1-8 | E1-10 |
| Anticipated financial effects | E1-9 | E1-11 |
Watch for two collisions:
- E1-6 used to mean emissions. Now it means targets.
- E1-8 used to mean internal carbon pricing. Now it means emissions.
Search results, auditor requests and internal trackers mix these up right now. When someone says "E1-6," check which version they mean.
Which version applies to you
Omnibus I (Directive 2026/470) took effect on 18 March 2026. It narrowed CSRD scope to companies with more than 1,000 employees and more than €450 million in net turnover. The Commission estimates that removes about 85% of companies from scope.
For the companies still in scope, the reporting year decides which version applies.
| Financial year | Standard | GHG disclosure label |
|---|---|---|
| FY2025 | ESRS 2023, with the 2025 "quick fix" reliefs | E1-6 |
| FY2026 | Your choice: ESRS 2023 (with some new reliefs) or the revised ESRS | E1-6 or E1-8 |
| FY2027 onward | Revised ESRS, mandatory | E1-8 |
If you report FY2026, you have to state which version you applied in your sustainability statement. Whichever you pick, name it clearly.
What the old E1-6 requires (current reporting)
If you're reporting FY2025, or choosing the old standard for FY2026, this is your rulebook.
Paragraph 44 requires four figures, all in tCO2eq:
- Gross Scope 1 emissions
- Gross Scope 2 emissions
- Gross Scope 3 emissions
- Total GHG emissions
Scope 1 has to include the percentage of emissions covered by regulated emissions trading schemes. That means the EU ETS, national schemes and non-EU schemes.
Scope 2 is reported twice, location-based and market-based. You also disclose the share and types of contractual instruments you use, such as guarantees of origin or RECs.
Scope 3 covers each significant category. You screen against the 15 GHG Protocol categories, then report the ones that matter. AR 46(g) also asks for the percentage of emissions calculated from primary data from suppliers or other value chain partners.
Total GHG emissions are shown twice, once using location-based Scope 2 and once using market-based. The datapoint list doesn't spell out the total, but EFRAG's Q&A (ID 109) confirms it's still required. It appears in both the bold paragraph and the objective.
GHG intensity is total emissions divided by net revenue (paragraph 53), shown for both Scope 2 methods.
The boundary is the consolidated group plus any assets under operational control.
Methods: GHG Protocol Corporate Standard (2004), the latest IPCC 100-year GWP values, and biogenic CO2 reported separately from Scopes 1 to 3.
Phase-in: companies with 750 employees or fewer can leave out Scope 3 and total emissions in their first reporting year.
What the new E1-8 requires
E1-8 keeps the core inventory and cuts much of what surrounded it.
What stays:
- Gross Scope 1, 2 and 3 emissions in tCO2eq
- The seven Kyoto gases: CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3
- The latest IPCC 100-year GWPs. If your emission factors only come with older GWPs, you can use them and say so.
- The GHG Protocol Corporate Standard as the baseline method. ESRS requirements take precedence where they conflict.
- Scope 2 still follows the GHG Protocol Scope 2 Guidance
What changes:
- Boundary flexibility. The Commission changed EFRAG's advice here. EFRAG proposed financial control only. The final text lets you choose a GHG Protocol consolidation approach. The Commission summary names financial and operational control. PwC reads it as also allowing equity share. ESRS 1 rules on leases, long-term employee benefit schemes and joint operations still apply when you set the boundary.
- Scope 1 ETS share narrows to the EU ETS. National and non-EU schemes no longer count toward the percentage. If you operate under the EU ETS, you follow the EU ETS methodology for those activities.
- No netting. Removals, purchased or sold carbon credits and GHG allowances stay out of the emissions figures.
- Biogenic CO2 is scaled back. Biogenic CO2 from burning or biodegrading biomass stays out of Scopes 1 to 3. Non-CO2 gases from biomass, such as CH4 and N2O, still count.
- Scope 3 refresh cycle. You update significant categories every year using current activity data. You update the full Scope 3 inventory at least every three years, or sooner after a significant change.
- The reporting table is optional. Presenting emissions against a base year is now a "may," not a "shall."
What's gone, based on EFRAG's advice and the drafts:
- The standalone total GHG emissions datapoint
- The GHG intensity per net revenue metric
Check these two against the version published in the Official Journal. It's expected around November 2026. The Commission's changes to GHG emissions went beyond the boundary rules, so confirm the final wording before you lock your templates.
Side by side: E1-6 vs E1-8
| Requirement | Old E1-6 (2023) | New E1-8 (2026) |
|---|---|---|
| Gross Scope 1, 2, 3 | Required | Required |
| Total GHG emissions | Required (location- and market-based) | Removed from the datapoint list |
| GHG intensity per net revenue | Required | Removed |
| Reporting table | Mandatory | Optional |
| Organisational boundary | Consolidated group plus operational control | Your choice of GHG Protocol approach |
| Scope 1 ETS percentage | All regulated ETS | EU ETS only |
| Biogenic CO2 | Reported separately | Reduced scope. Kept out of Scopes 1 to 3 |
| Scope 3 update cycle | Annual for significant categories | Annual for significant categories, full refresh at least every 3 years |
| Partial-scope relief (ESRS 1 para 91) | Not applicable | Explicitly excluded for E1-8 |
What this means for your emissions data system
1. Decide your boundary before you restate anything
Choosing a boundary is where E1-8 gives you the most flexibility, and where the risk is highest. If you switch from the old hybrid boundary to pure financial control, emissions from sites you operate but don't consolidate can move from Scope 1 into Scope 3.
That affects:
- Base-year comparability for your targets
- Targets you've already published, which now fall under the new E1-6
- Assurance, because your auditor will want the boundary change explained
Pick your approach, document the reason, and recalculate your base year if the change is material.
2. Keep collecting what you'll still need
Total emissions and intensity drop out of the datapoint list. Investors, lenders and ratings agencies will still ask for them, and your target tracking probably relies on total emissions. The sum is free to calculate, so keep it in your internal reporting.
3. Don't count on the value chain cap for emissions data
Omnibus I added a value chain cap. Suppliers with 1,000 employees or fewer can refuse information requests that go beyond the voluntary standard (VS). According to Cooley's reading of the final text, that protection doesn't cover E1-8 emissions data. You can still ask smaller suppliers for the emissions inputs you need for Scope 3.
The ESRS 1 relief for reporting a metric on a partial scope of the value chain also excludes E1-8. You can't report Scope 3 for just part of your value chain and call it complete.
4. Link your new E1-6 targets to your E1-8 inventory
Under the revised standard, targets (E1-6) and the inventory (E1-8) are separate disclosures. They still have to match. Use the same gases, scopes and boundary, or explain the differences. Targets stay gross, with no removals, credits or avoided emissions counted toward them.
Worked example: same company, two standards
Nordfab is a fictional company used for illustration. It's a mid-size industrial manufacturer with 2,400 employees and €600 million in revenue. It reports FY2026 under the old standard and FY2027 under the new one.
FY2026 under old E1-6
| Line | tCO2eq |
|---|---|
| Gross Scope 1 | 18,000 |
| Share under regulated ETS (EU ETS 62% plus UK ETS 4%) | 66% |
| Gross Scope 2, location-based | 9,500 |
| Gross Scope 2, market-based | 4,200 |
| Scope 3 Cat. 1, purchased goods and services | 110,000 |
| Scope 3 Cat. 4, upstream transport | 12,000 |
| Scope 3 Cat. 11, use of sold products | 35,000 |
| Total (location-based) | 184,500 |
| Total (market-based) | 179,200 |
| Intensity, location-based (tCO2eq per €M revenue) | 307.5 |
| Intensity, market-based (tCO2eq per €M revenue) | 298.7 |
Scope 1 includes 1,500 tCO2eq from a contract manufacturing site. Nordfab operates the site but a third party owns it. It's in Scope 1 because the old boundary adds operational control.
FY2027 under new E1-8
Nordfab chooses financial control. The contract site is outside the financial boundary, so its 1,500 tCO2eq move from Scope 1 into Scope 3 Category 1.
| Line | tCO2eq |
|---|---|
| Gross Scope 1 | 16,500 |
| Share under EU ETS (11,160 ÷ 16,500) | 67.6% |
| Gross Scope 2, location-based | 9,500 |
| Gross Scope 2, market-based | 4,200 |
| Scope 3 Cat. 1, purchased goods and services | 111,500 |
| Scope 3 Cat. 4, upstream transport | 12,000 |
| Scope 3 Cat. 11, use of sold products | 35,000 |
What changed on the page:
- Scope 1 fell by 1,500 t. The emissions didn't go away. They moved to Scope 3.
- The ETS share went up even though no installation changed. The UK ETS site no longer counts, and the Scope 1 base got smaller.
- Total and intensity are no longer required datapoints. Nordfab still reports them in a voluntary table because its lenders track them.
- Nordfab recalculates its Scope 1 target base year for the new boundary and explains the change.
If Nordfab chose operational control instead, Scope 1 would stay at 18,000 t. The choice changes the numbers, so document why you made it.
What to do now
- Confirm whether you're still in scope under the 1,000-employee and €450M thresholds.
- Decide which version you'll use for FY2026, and document the decision.
- Choose your E1-8 boundary and test what it does to your base year.
- Keep calculating total emissions and intensity internally.
- Plan supplier data requests for Scope 3. The value chain cap doesn't protect suppliers from emissions data requests.
- Check your templates against the Official Journal text when it's published.
If you're adding AI workloads to your Scope 3 inventory, my guide on calculating AI emissions for CSRD covers the method, data sources and disclosure wording.
Sources
- EFRAG Knowledge Hub: Simplified ESRS E1, Delegated Act version
- EFRAG Knowledge Hub: Simplified ESRS E1 Technical Advice, E1-8 ARs
- EFRAG Simplified ESRS Factsheets
- EFRAG ESRS Q&A Explanations 1-2024 (ID 109)
- European Commission C(2026) 5010, EUR-Lex
- Commission Staff Working Document SWD(2026) 500
- Council document 11667/26 ADD 1 (Annexes)
- PwC: ESRS (2026), a deep dive into the revised standards
- Cooley: European Commission Adopts Revised EU CSRD Reporting Standards
- EY: Exposure Drafts of simplified ESRS
- Rödl & Partner: Draft simplified ESRS, environmental changes
I help organizations turn ESRS requirements into reporting systems and disclosures that hold up under assurance. If the E1-6/E1-8 renumbering has left your emissions data in flux, let's talk.
Frequently Asked Questions
Is ESRS E1-6 still required?
Yes, for FY2025. For FY2026 it's required if you choose the 2023 standard. From FY2027 the GHG emissions disclosure moves to E1-8, and E1-6 becomes the GHG reduction targets disclosure.
What is ESRS E1-8?
It depends on the version. In the 2023 ESRS, E1-8 is internal carbon pricing. In the revised ESRS, E1-8 is "Gross scope 1, 2, 3 GHG emissions," which replaces the old E1-6.
Do I still have to report total GHG emissions?
Under the old E1-6, yes, for both Scope 2 methods. Under E1-8, the standalone total drops out of the datapoint list based on EFRAG's advice. Check the Official Journal text to confirm. Most companies will keep reporting it voluntarily.
Can I use the revised ESRS for FY2026?
Yes. You can apply the revised ESRS for financial years starting in 2026. You have to state which version you used.
Does the value chain cap cover Scope 3 data requests?
No. Suppliers with 1,000 employees or fewer can decline requests beyond the voluntary standard, but that protection doesn't extend to E1-8 GHG emissions data.
Which organisational boundary should I use under E1-8?
The revised standard lets you choose a GHG Protocol consolidation approach, where the old standard required a hybrid. Weigh comparability with past reports, how your targets are set up, and what your investors expect. Whichever you choose, disclose and explain it.