Disclosure Requirement E1-5 – Energy consumption and mix

  1. The undertaking shall provide information on its energy consumption and mix (33).

  2. The objective of this Disclosure Requirement is to provide an understanding of the undertaking’s total energy consumption in absolute value, improvement in energy efficiency, exposure to coal, oil and gas-related activities, and the share of renewable energy in its overall energy mix.

  3. The disclosure required by paragraph 35 shall include the total energy consumption in MWh related to own operations disaggregated by:

- (a) total energy consumption from fossil sources

- (b) total energy consumption from nuclear sources

- (c) total energy consumption from renewable sources disaggregated by:

i. fuel consumption for renewable sources including biomass (also comprising industrial and municipal waste of biologic origin), biofuels, biogas, hydrogen from renewable sources (34), etc.

ii. consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (50)

iii. consumption of self-generated non-fuel renewable energy

  1. The undertaking with operations in high climate impact sectors (35) shall further disaggregate their total energy consumption from fossil sources by:

    • (a) fuel consumption from coal and coal products

    • (b) fuel consumption from crude oil and petroleum products

    • (c) fuel consumption from natural gas

    • (d) fuel consumption from other fossil sources

    • (e) consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources (36)

  2. In addition, where applicable, the undertaking shall disaggregate and disclose separately its non-renewable energy production and renewable energy production in MWh.


(33) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from a mandatory indicator related to principal adverse impacts as set out by indicator #5 in Table I of Annex I of Commission Delegated Regulation (EU) 2022/1288 with regard to disclosure rules on sustainable investments (“Share of non-renewable energy consumption and production”). The breakdown serves as a reference for an additional indicator related to principal adverse impacts as set out by indicator #5 in Table II of the same Annex (“Breakdown of energy consumption by type of non-renewable sources of energy”).

(34) Compliant with the requirements in delegated acts for hydrogen from renewable sources: Commission Delegated Regulation of 10 February 2023 supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council by establishing a Union methodology setting out detailed rules for the production of renewable liquid and gaseous transport fuels of non-biological origin; and Commission Delegated Regulation of 10 February 2023 supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council by establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin and from recycled carbon fuel.

(35) High climate impact sectors are those listed in NACE Sections A to H and Section L (as defined in Commission Delegated Regulation (EU) 2022/1288).

(36) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from a mandatory indicator related to principal adverse impacts as set out by indicator #5 in Table I of Annex I of Commission Delegated Regulation (EU) 2022/1288 with regard to disclosure rules on sustainable investments (“Share of non-renewable energy consumption and production”).

(50) Based on Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources.