CSRD reporting: how are you preparing for the first disclosure cycle?
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The Corporate Sustainability Reporting Directive (CSRD) first reporting deadline is approaching, and frankly, the scope of the European Sustainability Reporting Standards (ESRS) is overwhelming.
We're a mid-cap company that will fall under the second wave of reporting. Currently trying to:
- Complete our double materiality assessment
- Identify data gaps across environmental, social, and governance metrics
- Set up data collection processes across our subsidiaries
How far along are others in their preparation? Any tools or consultancies you'd recommend?
We're in a similar position. Here's where we are:
Double materiality assessment: This is the foundation of everything. We engaged an external consultant to facilitate stakeholder engagement and the impact/financial materiality analysis. It took about 3 months but was worth it — it significantly narrowed the number of ESRS data points we actually need to report on.
Data gaps: Enormous, especially on Scope 3 emissions and social metrics in our supply chain. We're being honest about what we can and can't measure in year one and building a roadmap for improvement.
Tool: We're using Workiva for ESRS reporting. It integrates well with our existing financial reporting workflow. Others in our industry are using Sphera or Persefoni for the environmental data specifically.
The key advice I'd give: don't try to boil the ocean. Focus on your material topics and build from there.
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One practical tip: start your value chain mapping now if you haven't already. CSRD/ESRS requires reporting on upstream and downstream impacts, and getting data from suppliers is incredibly time-consuming.
We sent out a supplier sustainability questionnaire 4 months ago and the response rate was initially under 20%. It took significant follow-up (and sometimes contractual leverage) to get meaningful data.
A few things to keep in mind for first-time CSRD reporting:
Gap analysis before anything else — Before you start building reports, do a systematic gap analysis against the ESRS standards applicable to your material topics. For each datapoint, document: (a) do we have this data? (b) where does it live? (c) is it audit-quality? This gives you a clear workplan rather than trying to tackle everything at once.
Assurance readiness — CSRD requires limited assurance initially, moving toward reasonable assurance over time. The difference matters for how rigorous your data collection and documentation needs to be. Limited assurance means your auditor checks that the data is plausible and the process is reasonable. Reasonable assurance (coming later) means they verify accuracy at the source level.
Technology decisions — You'll need some kind of data collection platform unless your company is very small. Spreadsheets work for year one but they don't scale and they're a nightmare for audit trails. Many ESG reporting platforms now support ESRS-specific templates. The investment is worth it if you'll be reporting for years to come.
Stakeholder communication — Don't forget that your CSRD report is public. Think about the narrative as much as the data. Investors, customers, employees, and regulators will all read it through different lenses. A report that's technically compliant but reads like a data dump misses the communication opportunity.
The first disclosure year is genuinely the hardest. It gets significantly easier once you've established baseline data and repeatable processes.
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