CSRD Reporting Process Explained and How Greenomy Can Help

Complying with the CSRD is a comprehensive task, and the numerous disclosures and customisable nature of sustainability reports add their own set of challenges, presenting both advantages and drawbacks.

On the one hand, the CSRD’s approach to materiality allows organisations to exclude information that does not pertain to their activities, there are numerous disclosures subject to phase-ins, and entity-specific disclosures enable companies to explain their Impacts, Risks, and Opportunities (IROs) more effectively. There is also flexibility regarding reporting policies, actions, and targets, or the lack thereof. On the other hand, given that compliance is mandatory, the report must be accurately completed on the initial attempt, regardless of the customisation opportunities available.

This article highlights the different stages of the CSRD reporting process, from the Double Materiality Assessment to the reporting under the ESRS, and how the Greenomy solution helps mitigate these issues.  

A Quick Recap on the CSRD

On January 5th, 2023, the Corporate Sustainability Reporting Directive (CSRD) entered into force, effectively replacing the Non-Financial Reporting Directive (NFRD) while broadening its scope of reporting. The CSRD seeks to enhance the transparency and comparability of ESG data across the EU and enable investors, analysts, consumers, and other stakeholders to evaluate EU companies' sustainability performance and allow for more informed decision-making. 

The Directive introduces several innovative concepts to ESG reporting, with two particularly significant advancements. Firstly, the principle of Double Materiality, which requires companies to evaluate sustainability issues from two perspectives: Impact materiality and financial materiality. Secondly, the European Sustainability Reporting Standards (ESRS), which seek to standardise the format for reporting ESG data, improving how companies communicate their impacts, risks, and opportunities.

The  European Sustainability Reporting Standards are divided into two sets: the sector-agnostic and the sector-specific standards. The sector-agnostic ESRS are composed of cross-cutting standards, detailing the architecture of the standards and disclosures at the general level, and topical standards which are further split into E, S, and G, and outline disclosures for different sustainability topics. On the other hand, the sector-specific ESRS will outline disclosures for different sectors, but they are currently in development and due in 2026.

Break Down of the CSRD Reporting Process

As the structure of the CSRD is complex and technical, the path to compliance can be challenging without the right tools. With over +1,200 data points to disclose, it is common for organisations to require assistance to achieve compliance. Let’s break down the different stages of the CSRD report generation.

Double Materiality and ESRS Disclosure Requirements

The Double Materiality Assessment (DMA) marks the start of the CSRD reporting exercise. During the DMA, companies undertake the foundational task of identifying and categorising their Impacts, Risks and Opportunities (IROs) to evaluate their materiality from both impact and financial perspectives. Upon completion, undertakings have to define the scope of their sustainability report based on the results of their DMA. Depending on their material IROs, undertakings can omit substantial parts of the ESRS and focus on the topics relevant to their material IROs. 

Identifying and classifying IROs calls for a thorough analysis of the undertaking’s operations and value chain activities. Compiling an exhaustive list of IROs within their own activities can be difficult due to the availability and quality of existing data, or a lack of channels that facilitate cross-departmental cooperation. 

The data collection challenges encountered within an organisation's operations are often mirrored and exacerbated across the value chain. Initially, a comprehensive map of the value chain is required. Then, accurate data access demands close collaboration with suppliers and partners, as well as maintaining meaningful communication with stakeholders. Additionally, some stakeholders may be reluctant to disclose certain information, either because business partners lack mechanisms or channels to fully understand the extent of their IROs or due to differing regulatory requirements.

Gap Analysis to Prepare the Reporting 

Once companies have defined their reporting scope, they must evaluate the gaps between their current available data and what they are required to disclose to comply with the CSRD, both in terms of quality and quantity. The Gap Analysis is crucial for project planning as it allows companies to identify where the data is and those responsible for particular data streams. 

A properly conducted Gap Analysis should equip the organisation with a set of existing datasets, a list of identified gaps to address, and a plan to mitigate these gaps. Conversely, if the Gap Analysis is inadequately prepared, the reporting team may face difficulties in streamlining the organisation around the reporting process. This could make the reporting exercise tedious and susceptible to delays, with potential oversights in both the identification of gaps and the use of existing data.

ESG Data Disclosures under the CSRD

After undertakings have mapped their IROs, identified the relevant gaps in their data, and mitigated them as much as possible, the next step is to populate the report according to the formats required by the CSRD. 

The degree of interconnection between the ESRS makes the framework particularly complex. The interconnections mainly stem from the cross-cutting standards presented in the first section of this article, which inherently affect all standards. Numerous interactions are also found across the topical standards, and these may vary for each company. 

Additionally, the ESRS introduced entity-specific disclosures, allowing companies to create additional disclosures to explain IROs that may not be covered, or covered with sufficient granularity, in the existing standards. These disclosures add a layer of customisable connections between standards

Example
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For instance, consider that it was assessed that “acid drainage” is a material topic for an organisation as sulfide minerals are exposed to the elements in a few of its sites, producing sulfuric acid that is reaching a nearby water source. The ESRS do not mention such topic, thus the company will have to define its own data point for reporting. 
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These data points could be the description of the policies or actions and resources put in place to manage acid drainage in the sites involved. It could also be the introduction of metrics into the reporting such as disclosing in which mining sites acid drainage is predicted to occur or has been found to occur; has not been actively mitigated; and is not under treatment or remediation.

The sector-specific ESRS dedicated to Mining, Quarrying and Coal will cover the topic of acid drainage. Until the dedicated standard is adopted organisations that deal with acid drainage as a material topic have to report this information by creating an entity-specific disclosure and disclosing this information alongside the most relevant topical ESRS.

The second set of ESRS, sector-specific standards, will add numerous new disclosures for different sectors and standardise some of the data currently reported under the entity-specific disclosures. However, these standards were delayed until 2026.

How Greenomy Helps at Each Stage of the CSRD Reporting Process

Successful reporting under the CSRD is a challenging endeavour with significant long-term opportunities. Compliance requires enhancements in data management, cross-departmental communication, and a deep understanding of own operations. These changes ultimately help identify operational inefficiencies and improve transparency, which builds trust with stakeholders and aligns with societal values. Refining existing processes helps ensure compliance and bolster a company’s appeal to investors, potentially reducing capital costs and attracting more investment, thereby transforming regulatory compliance into a strategic asset.

The Greenomy solution is specifically designed to address these requirements taking the resources available to organisations into account. Our solution for companies facilitates CSRD reporting, allowing undertakings to focus on the impacts of their activities, the risks to mitigate, and the opportunities to pursue to eventually efficiently plan their transition toward a more sustainable activity. 

CSRD Preliminary Assessment

Greenomy’s preliminary assessment, the initial step for companies' CSRD reporting, narrows the scope of the regulation to focus only on data points relevant to the organisation. It consists of a short questionnaire designed to identify data points applicable under certain conditions, filtering out the ESG indicators that do not apply to a particular company based on the answers provided.

The platform provides a comprehensive and detailed list of elements that must be included in the sustainability statement, along with those that can be omitted based on specific criteria such as company size or material IROs. Additionally, the platform allows companies to add the justification for each data point

Ultimately, the preliminary assessment step helps companies quickly identify the required data points for compliance, which is a subset of the total, rather than the total of 1,500 metrics.

Greenomy’s Gap analysis

Upon finalising the scope of their reporting through the preliminary assessment, companies will be able to distinguish between mandatory and voluntary data points, identify critical gaps, proactively focus on areas for improvement, and distribute tasks within their organisations.

The Gap Analysis is a crucial step wherein the reporting team familiarises itself with CSRD requirements, identifies the owners responsible for particular data streams, communicates the necessary data to be included from various stakeholders, and overall streamlines the organisation around the reporting process. Greenomy’s Gap Analysis tool provides a clear and comprehensive overview of the data required for ESRS reporting, tailored to each organisation.

For each ESRS, a table provides the exhaustive list of data points defined by the European Financial Reporting Advisory Group (EFRAG) with detailed information on their type and the reason why the disclosures are voluntary or mandatory based on the preliminary assessment.

Users can initially concentrate on the mandatory requirements for their organisation and delve into each requirement to better understand where gaps exist. This approach allows for a more efficient and effective data collection process, addressing any identified gaps. 

Once a gap is identified, the reporting manager can leverage Greenomy’s workflow tool to create actions, distribute ownership, and plan the gap remediation in the tool. This process streamlines the engagement of each unit within the organisation, facilitating and accelerating data collection for reporting.

ESRS Reporting Leveraging Greenomy

Finally, after remediating the gaps, the company is ready to start its sustainability reporting journey. The ESRS Reporting solution equips the organisation with all the necessary tools to produce its sustainability statement according to the CSRD.

Within the tool, the company will find both cross-cutting and topical standard ESRS, along with additional resources to aid in understanding the requirements and accurately disclosing data.

For each disclosure requirement, users will have access to the original regulatory text and an exhaustive list of disclosures they must fulfill, as defined by the EFRAG. Additional information to assist users in comprehending the requirements, such as defined terms, guidelines, or application instructions, is available for each disclosure requirement and is readily accessible.

To efficiently navigate the ESRS and leverage the interconnections between disclosure requirements for the reporting, users are also provided with the relevant related disclosures. This feature helps users easily consolidate their responses and ensure the consistency of their sustainability statements.

To assist users along their reporting journey, Greenomy offers the support of Artemis, your AI Sustainability Advisor. Artemis answers any questions about the CSRD to help users understand the legislation or learn about the best practices in their industry. Leveraging generative AI, Artemis also helps undertakings answer requirements based on the undertaking’s documents.

Organisations can also engage all stakeholders in the data collection and reporting process. Tasks can be created, and specific data requests sent to relevant individuals to efficiently plan the reporting journey, ensuring readiness with minimal effort.

Finally, ensure the quality of your sustainability statement through a four-eyes check and validation process. Once stakeholders have entered the required data and finalised their responses, validate the data to ensure its integrity before the publication of the sustainability statement.

Greenomy to Reduce your CSRD Reporting Burden

All in all, CSRD compliance can be a daunting endeavour but, leveraging the right technology, it comes with an undeniable set of opportunities to improve the strategies, operations, and overall systems of organisations. 

The Greenomy solution is specifically designed to equip companies with all the necessary tools to efficiently produce the sustainability report following the requirements defined by the CSRD while alleviating the reporting burden. From defining the reporting scope through the preliminary assessment to producing a complete and compliant ESG statement, and addressing gaps identified in the gap analysis, Greenomy guides your organisation at every stage of the reporting journey.

In addition to the CSRD solution, Greenomy tackles the challenge of data collection, which can be tedious and time-consuming due to the various data sources and formats, with Artemis, our AI Sustainability Advisor, and the ESG Data Library. These tools facilitate the integration of ESG data and automatically populate your sustainability statement. Book a call for further details.