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As the 2025 deadline for the first set of ESRS disclosure looms, several European companies are gearing up to meet these new mandatory ESG disclosure requirements.
But navigating the Corporate Sustainability Reporting Directive (CSRD) can be challenging, especially for businesses (and buyers and auditors) that are just getting started with this process.
This short guide is here to provide you with handy tips that will not only help you adhere to regulations, but also use them to promote long-term sustainability and business growth.
Who will take charge of CSRD disclosures? Will this be handled by an internal task force, or outsourced to external experts (consultants, law firms, etc.)?
Initially, leveraging external consulting firms and other external partners can be extremely handy and helpful, providing the regulatory expertise needed to jumpstart your compliance efforts. Their expertise can also be used to accelerate the training of your internal team on all things CSRD reporting (and beyond).
However, to ensure the long-term sustainability of your ESG reporting efforts, you should consider establishing an in-house ESG team that is specifically tasked with managing and overseeing CSRD reporting. Unlike external experts, your internal team can help build your company-specific ESG knowledge base over time, which is crucial for crafting a long-term, actionable ESG strategy. As they become more proficient with the subject-matter and with how it related to your company’s unique context, they will also be able to champion ESG initiatives and actions - which will ultimately help you truly transform your business for the better.
A small note here: If you are strapped on resources, you don’t need a huge team to get started. With the help of technology for CSRD compliance, you can get a head start with the whole process even with a smaller core team.
Materiality is not merely the starting point for ESRS disclosures; it is a core component.
Simply speaking, “assessing materiality” involves identifying which ESG issues are most significant to your business, helping to prioritize them for both reporting purposes and operational focus.
While it may seem straightforward, conducting a materiality assessment is complex and the exact process and factors to be taken into account can vary slightly depending on the framework adopted.
In ESRS disclosures, the concept of "double materiality" — which encompasses the three pillars of Impacts, Risks, and Opportunities — is central. This expanded scope makes materiality assessments under the ESRS slightly more challenging than materiality under the GRI and the IFRS - which consider, respectively, only the “impact” and the “financial risks and opportunities” side. However, the ESRS have been developed with a focus on interoperability with other frameworks, and especially with the widely-adopted GRI. So if having already engaged with materiality in the context of voluntary reporting will give you a considerable advantage when reporting under the ESRS.
Another essential part of any materiality assessment entails engaging with both internal and external stakeholders to gather diverse perspectives, which can be particularly challenging for complex organizations - where the first step is effectively identifying who those key stakeholders are. In this regard, the ESRS actually talks about two main sets of stakeholders: “user of ESRS disclosures”, and “affected stakeholders”. These include a very broad set of stakeholders, ranging from NGOs to financial institutions, from employees to boards.
Clearly, there is a lot to unwrap here, and materiality assessments are just a starting point - the diverse stakeholders’ viewpoints will need to be progressively integrated in your company’s ESRS reporting and business strategy and actions.
As a final point: the CSRD follows a “comply or explain” approach - meaning that labelling any issue as “not material” to the company needs to be carefully explained and justified within the report.
We have already touched on this when talking about materiality, but to put it straight:
The granularity required by ESRS can be daunting. The draft datapoints released be EFRAG as a support to ESRS reporting include, alone, over 1100 datapoints. This doesn’t take into account ancillary reporting requirements set out by the CSRD, such as EU Taxonomy reporting.
Although the initial materiality assessments will help narrow down the scope of reporting, for some companies, the volume of data that needs to be collected, condensed, and organized into a comprehensive audit trail can still be overwhelming.
Integrating technological tools is key to managing this complexity effectively. At Briink, we develop AI tools that support companies, auditors, and investors at various stages of their CSRD reporting journey to effectively collect, verify and re-work ESG data from past reports, financial reports, energy documents etc. These tools are designed to augment and empower internal ESG teams, enabling them to achieve more with fewer resources.
We will never stress this enough: CSRD reporting is not meant to culminate in a glossy marketing asset; its ultimate purpose is to drive transparency around ESG matters, but it should also be harnessed to drive tangible change within companies.
Because CSRD reporting requires significant effort, it should be used as a tool to enhance long-term corporate sustainability and value - to ensure that the reporting process itself becomes a strategic asset rather than just a compliance exercise.
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