CSRD

Sustainability reporting must be subject to assurance, beginning with limited assurance and moving towards reasonable assurance once standards are adopted; the assurance is provided by a statutory auditor or an independent assurance services provider.

• Limited (later reasonable) assurance report over the sustainability statement
• Evidence of the assurance provider's independence and competence

• No assurance obtained over sustainability information
• Assurance scope not covering the full ESRS statement

The sustainability statement must be prepared in the single electronic reporting format (XHTML) and digitally tagged according to the ESRS digital taxonomy so the information is machine-readable.

• XHTML sustainability statement with ESRS XBRL tagging
• Validation of the digital tags against the ESRS taxonomy

• Untagged or PDF-only sustainability statement
• Tagging errors against the ESRS taxonomy

Reporting obligations apply in waves (large public-interest entities first, then other large undertakings, then listed SMEs), with specified transitional reliefs and first-year phase-in disclosures.

• Mapping of the entity's first reporting year and applicable transitional reliefs
• Tracking of phase-in disclosure obligations

• Reporting late against the applicable wave
• Claiming transitional relief not available to the entity

The CSRD extends sustainability reporting obligations to large undertakings and listed SMEs, phased in by size/type, requiring sustainability information in a dedicated section of the management report, including on a consolidated (group) basis where applicable.

• Determination of in-scope status and the applicable phase-in date
• Consolidation/group reporting boundary for sustainability information

• Misjudging in-scope status or phase-in timing
• Omitting subsidiaries from group sustainability reporting

In-scope undertakings must disclose the proportion of their turnover, capital expenditure and operating expenditure that is associated with environmentally sustainable economic activities under the EU Taxonomy, using the Article 8 templates.

• Taxonomy-alignment KPIs (turnover/CapEx/OpEx) using the Article 8 templates
• Supporting evidence for substantial-contribution and DNSH assessments

• Missing or incomplete Taxonomy KPIs
• No DNSH or minimum-safeguards assessment

Undertakings must determine the sustainability matters to report using double materiality: a matter is material if it is material from an impact perspective (effects of the undertaking on people/environment) or a financial perspective (effects on the undertaking), or both.

• Documented double materiality assessment and its outcomes
• Stakeholder engagement and IRO inputs to the assessment

• Single (financial-only) materiality lens
• No documented basis for material/immaterial determinations

Disclosures must apply the defined short-, medium- and long-term time horizons and the prescribed reporting period and boundaries, ensuring comparability across periods.

• Consistent application of the ESRS time horizons
• Defined reporting period and boundary in the statement

• Inconsistent or undefined time horizons

Where material, disclosures must cover the undertaking's upstream and downstream value chain, using estimation and transitional reliefs where direct data is not yet available.

• Value-chain coverage of material disclosures
• Documented use of estimation/transitional reliefs for value-chain data

• Value chain omitted for material matters
• No methodology for value-chain estimates

Disclose the role of the administrative, management and supervisory bodies in sustainability, including their composition, expertise, oversight of impacts/risks/opportunities, and the integration of sustainability into incentive schemes.

• ESRS 2 governance disclosures (body roles, expertise, oversight)
• Evidence of board oversight of sustainability IROs

• No disclosure of governance roles in sustainability
• Sustainability not on the board agenda

Disclose the process to identify and assess material impacts, risks and opportunities, and how they are managed, including the policies, actions, metrics and targets adopted in response.

• IRO identification and assessment process documentation
• Linkage of IROs to policies, actions, metrics and targets

• No structured IRO process
• Material IROs without associated policies/actions

Disclose the undertaking's strategy and business model, including how sustainability-related impacts, risks and opportunities interact with strategy, and the interests of key stakeholders.

• ESRS 2 strategy/business-model disclosures
• Stakeholder-interest analysis

• Strategy disclosure disconnected from sustainability IROs

Disclose climate-change mitigation and adaptation, including a transition plan compatible with limiting warming to 1.5 C, climate targets, and the financial effects of climate-related risks and opportunities.

• ESRS E1 transition plan and climate targets
• Climate scenario analysis and financial-effect disclosures

• No transition plan where E1 is material
• Targets not science-aligned

Disclose gross Scope 1, Scope 2 (location- and market-based) and Scope 3 greenhouse gas emissions, total GHG emissions, and the methodologies and boundaries used, consistent with the GHG Protocol.

• Scope 1/2/3 GHG inventory with methodology and boundaries
• Independent check or recalculation of the GHG figures

• Scope 3 omitted where material
• Inconsistent or undocumented GHG methodology

Disclose pollution of air, water and soil, substances of concern and of very high concern, and the policies, actions and targets to prevent and control pollution.

• ESRS E2 pollution disclosures and targets
• Inventory of substances of concern

• Pollution disclosures omitted where material

Disclose water consumption and withdrawals, water management in areas of water stress, and impacts on marine resources, with related policies, actions and targets.

• ESRS E3 water and marine disclosures
• Water-stress area analysis

• Water disclosures omitted where material

Disclose impacts and dependencies on biodiversity and ecosystems, including impacts on land use, species and protected areas, with transition plans, policies, actions and targets.

• ESRS E4 biodiversity impact and dependency assessment
• Biodiversity transition plan where material

• Biodiversity dependencies not assessed

Disclose resource inflows and outflows, waste, and the application of circular-economy principles, with related policies, actions and targets.

• ESRS E5 resource-flow and waste disclosures
• Circular-economy policies and targets

• Resource/waste disclosures omitted where material

Disclose business-conduct matters including corporate culture, protection of whistleblowers, anti-corruption and anti-bribery, political engagement, supplier-relationship and payment practices, with related policies and actions.

• ESRS G1 business-conduct disclosures (anti-corruption, whistleblowing, payment practices)
• Anti-bribery policy and whistleblower channel

• No anti-corruption or whistleblower disclosure

Disclose impacts on the undertaking's own workforce, including working conditions, equal treatment and opportunities, health and safety, and other work-related rights, with policies, actions, metrics and targets.

• ESRS S1 own-workforce metrics (diversity, H&S, pay)
• Policies and remediation channels for workforce impacts

• Workforce metrics incomplete
• No grievance mechanism for own workforce

Disclose material impacts on workers in the upstream and downstream value chain, and the policies, due diligence, actions and targets to address them.

• ESRS S2 value-chain worker impact assessment
• Supplier due-diligence and remediation evidence

• Value-chain worker impacts not assessed

Disclose material impacts on affected communities, including economic, social and cultural rights, civil and political rights, and the rights of indigenous peoples, with related policies and actions.

• ESRS S3 affected-community impact assessment
• Community engagement and grievance mechanisms

• Community impacts not assessed where material

Disclose material impacts on consumers and end-users, including information-related, personal-safety and social-inclusion impacts, with related policies, actions and targets.

• ESRS S4 consumer/end-user impact assessment
• Consumer safety and grievance evidence

• Consumer impacts not assessed where material