A step-by-step guide to implementing an effective CSRD reporting framework

The Corporate Sustainability Reporting Directive (CSRD) represents a significant shift in corporate sustainability reporting within the European Union. As environmental, social, and governance (ESG) factors become increasingly critical to investors, consumers, and policymakers, the CSRD aims to standardise and enhance the quality of sustainability disclosures. By mandating comprehensive reporting on a company's environmental and social impacts, as well as how sustainability issues affect its financial performance, the CSRD seeks to improve transparency, accountability, and comparability across businesses.

If your business is impacted by the CSRD, the following process for developing a comprehensive reporting strategy outlining your approach to sustainability reporting can help to ensure compliance and maximise the benefits of sustainability reporting.

Conduct a double materiality assessment

Performing a comprehensive double materiality assessment is the crucial first step in building a reporting framework under CSRD. This process involves evaluating both the impact of your business on environmental, social and governance issues, and how these issues affect your financial performance. The assessment should engage various stakeholders, including employees, customers, suppliers, and local communities, to identify the most relevant sustainability topics for your company.

This step ensures that your reporting focuses on the most material issues, providing a solid foundation for your CSRD compliance efforts and your sustainability strategy.

Gap analysis and data collection strategy

Once material topics are identified, conduct a thorough gap analysis to identify your disclosure requirements and compare your current reporting practices with CSRD requirements. This step is essential for identifying areas where your data collection and reporting processes fall short of the new standards.

Developing a comprehensive strategy to address these gaps, which may include establishing new data collection methods, data mapping to understand where data is coming from and being stored and any calculations being performed, enhancing existing systems, and assigning responsibilities for each data point, ensures that you have the necessary infrastructure and processes in place to gather all required information efficiently and accurately.

Align with ESRS and develop KPIs

Familiarise yourself with the ESRS and align your reporting framework accordingly. The ESRS provides a standardised set of disclosure requirements that cover a wide range of sustainability topics.

Based on these standards and your materiality assessment, develop key performance indicators (KPIs) that accurately reflect your company's sustainability performance. These KPIs should be specific, measurable, and relevant to your industry and operations. Ensure that your chosen metrics cover all material topics identified in your assessment and provide a clear picture of your company's ESG impacts and progress.

Establish governance and oversight

Creating a robust governance structure is crucial for overseeing the sustainability reporting process and ensuring its integration into overall business strategy. Define clear roles and responsibilities within your organisation for managing sustainability reporting, including board-level oversight, will demonstrate the importance of sustainability to your company's leadership.

Internal controls and review processes should be established to maintain the accuracy and reliability of your sustainability data and disclosures. A strong governance framework not only supports compliance with CSRD but also enhances the credibility of your sustainability efforts.

Implement data management systems

Investing in or upgrading your data management systems is essential for efficiently collecting, processing, and storing sustainability data. Consider implementing specialised software or integrating sustainability data into existing enterprise resource planning (ERP) systems. These systems should be capable of handling the complexity and volume of data required for CSRD reporting, ensuring data accuracy, consistency, and auditability.

Effective data management is crucial for producing reliable sustainability reports and facilitating the assurance process required by CSRD.

Develop reporting processes and timelines

Establish clear processes and timelines for collecting data, drafting reports, and conducting internal reviews. Integrating sustainability reporting into your annual reporting cycle to ensure it receives the same level of attention and rigor as financial reporting helps streamline the reporting process and ensures compliance with CSRD's regular reporting requirements. Guidelines for data inclusion, document formatting, and a timeline for report preparation that aligns with your financial reporting schedule should also be developed.

Prepare for assurance

As the CSRD requires third-party assurance of sustainability reports, it's crucial to prepare your reporting framework for external verification from the outset. Prepare by documenting your reporting processes meticulously, maintaining clear audit trails, ensuring the traceability of all reported data, and engage with assurance providers early to understand their requirements and expectations. This preparation will help ensure the credibility and reliability of your sustainability disclosures and smooth the assurance process.

Continuous improvement and stakeholder engagement

An ongoing process for regularly reviewing and improving your reporting framework, as well as continual engagement with stakeholders, helps ensure your reporting remains relevant, effective, and aligned with evolving stakeholder expectations and regulatory requirements. Staying informed about updates to the ESRS and other relevant standards is essential to ensure your reporting framework remains compliant and best-in-class.

By taking these actions, businesses can build a robust reporting framework under CSRD to enhance the transparency of their ESG and sustainability performance.

If you have any questions related to the Double Materiality Assessment, the Corporate Sustainability Reporting Directive (CSRD),  or any other ESG and sustainability matters, please contact our ESG services team.