CSRD Reporting Data: What ESRS Requires From Finance

CSRD reporting: the data behind the disclosuresCSRD moves sustainability information into the management report, under assurance, on the same timeline as the financial statements. The hard part is not the narrative — it is sourcing hundreds of quantitative data points from systems that were never designed to be audited, and giving each one an owner, a definition, and a trail.The Corporate Sustainability Reporting Directive (EU) 2022/2464 requires in-scope companies to report under the European Sustainability Reporting Standards (ESRS), developed by EFRAG. Scope and timing have been amended by the 2025 'stop-the-clock' directive, so the first question for any group is which wave it now falls into and from which financial year.Whatever the date, the data work is the same, and it lands on finance. Sustainability data has to reach the same standard of traceability as financial data: defined, sourced, controlled, and reproducible.Start with double materiality, not with data collectionESRS 1 requires a double materiality assessment — impact materiality and financial materiality — and that assessment determines which topical standards and which data points apply. Collecting data before the assessment is finished is the most common way to waste a first reporting cycle.The output you want is a datapoint register: every disclosure requirement judged material, mapped to a definition, a source system, an owner, and a control.Where the data actually sits

ESRS E1 (climate): energy and fuel consumption in facilities systems and utility invoices; Scope 3 largely in procurement and AP spend data

ESRS S1 (own workforce): headcount, turnover, pay gap, training hours in HR and payroll systems — with entity and country granularity finance rarely reports on today

ESRS E5 (resource use): waste and materials data in operational systems, often per site and outside any ERP

ESRS G1 (business conduct): policy, incident, and payment-practice data spread across legal, compliance, and AP

Value chain data from suppliers, which has no internal system of record at all and needs a collection and challenge process

The controls assurance will look forCSRD requires limited assurance initially, with the possibility of a move to reasonable assurance. Practically, an assurance provider will test the same things they test on financial data.

A written definition per data point, including boundary, unit, and estimation method

Consistent entity scope between the financial statements and the sustainability statement, with differences explained

Evidence for estimates and emission factors, including the version and source of the factor set

Segregation between data preparers and reviewers, with sign-off captured

Restatement policy and a change log for definitions and methods

Digital tagging readiness for the ESEF/XBRL taxonomy for sustainability information

Treat it as a reporting cycle, not a reportSustainability data collected once a year, by email, from site managers, cannot be assured efficiently. The groups that get through the first cycle without pain move to quarterly collection with the same close discipline as financial data — a calendar, a system of record, and exception reporting on missing or implausible values.CSRD data readiness checklist

Confirmed scope and first reporting year under the current directive timeline

Completed double materiality assessment, documented and approved

Datapoint register: disclosure requirement, definition, unit, boundary, owner, source system

Entity scope reconciled to the consolidation scope, with differences documented

Source system inventory per data point, including systems outside finance

Emission factor set documented with version and source

Estimation methodology written down per estimated data point

Collection calendar aligned to the financial close

Review and sign-off workflow with preparer/reviewer segregation

Restatement and change-log policy for definitions and methods

Gap list for value chain data with a supplier collection plan

XBRL tagging approach for the sustainability statement

How we would approach this

We build the datapoint register first and treat it as the control document for the whole programme.

We connect data points to systems of record rather than to spreadsheets, so the second reporting cycle costs a fraction of the first.

We involve the assurance provider on methodology early — the questions they ask in year one are cheaper to answer in design than in fieldwork.

What data does CSRD reporting actually require?ESRS datapoints across environmental, social and governance topics that survived the double materiality assessment, each with a defined source, calculation basis and retained evidence, covering own operations and the relevant parts of the value chain.Does CSRD data need to be auditable?Yes. Sustainability reporting under CSRD is subject to assurance, starting at limited assurance, so ESG data needs the same lineage, control and retention discipline as financial data.Primary sources

Directive (EU) 2022/2464 (CSRD) — https://eur-lex.europa.eu/eli/dir/2022/2464/oj

EFRAG — ESRS standards and guidance — https://www.efrag.org/en/sustainability-reporting

European Commission — corporate sustainability reporting — https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en