From Compliance to Impact: Short-Term Data Strategies for Implementing CSRD

Throughout history, financial reporting has undergone significant evolution to harmonise reporting standards. Today, with the introduction of the Corporate Sustainability Reporting Directives (CSRD), organisations are confronted with a fresh set of challenges and a pressing need for adaptability.

The CSRD introduces a broadened scope for reporting, not limited to conventional financial data. Moreover, it spans a wider range of environmental, social, and governance (ESG) metrics. The overarching question facing many organisations is: What strategies can organisations adopt to meet the broad demands of CSRD implementation, particularly when they are still in the early stages of gathering the essential data? 

Transitioning to CSRD compliance is not a straightforward journey. Integrating time-tested financial data with the novel ESG metrics introduces complexities, especially when some data points remain elusive. Examples include data on gender pay-gap, emissions to water and the share of non-renewable energy consumption. It is essential for institutions to ensure their interim reports strike a balance—being transparent but ensuring accuracy and completeness.  

In navigating these complications, two key areas emerge: the role of understanding data and the shift to impact reporting. Let us delve into each of these. 

Data is fundamental to CSRD reporting, but it is not a matter of sourcing external data and embedding it directly into disclosures. Companies must internalise the diverse viewpoints presented by the data, drawing their own interpretations and understanding. This approach mirrors the lessons learned from credit agencies post-financial crisis, emphasising the importance of internal scrutiny and interpretation over mere external acquisition.  

As institutions hustle to gather the varied metrics CSRD demands, they might encounter gaps. It is a common misconception that one can simply fill assessment gaps with raw data. Here, “greenwashing” – the practice of providing a misleading impression about an organisation’s sustainability practices – is a growing concern. Genuine, accurate, and insightful data reporting is more crucial than ever. Misrepresenting or misinterpreting data not only risks non-compliance but also jeopardizes an institution’s reputation and trustworthiness in the eyes of stakeholders. On the contrary, data must be contextualised, interpreted, and understood within the broader framework of CSRD. 

In the subsequent paragraphs, we will dive deeper into short-term strategies that can help your organisation navigate this landscape. 

Harness current datasets and utilise the strength of existing data flows, such as client application forms or asset approval workflows. Swiftly incorporating new standardised fields not only meets CSRD prerequisites but also delves deeper into the organisation’s ESG performance. Given the current manual-intensive nature of compliance, institutions might find themselves without specific metrics on hand. In such cases, leaning on proxy data or estimates becomes essential. Even though these serve as temporary measures, understanding their implications and limitations is crucial.

When resorting to proxies or estimates, articulate this clearly in reports. It helps stakeholders recognise the report’s evolutionary nature and its broader context. More than just sharing data points, it is vital to communicate the insights they yield. 

In the short-term, compliance can be labour-intensive, placing a significant burden on staff. Adopting tactical methods not only alleviates this strain but also lays down a foundation for future strategic solutions, making the eventual transition smoother and more efficient.

The floods in Limburg in 2021 and extended droughts in 2022 demonstrate the need for organisations to analyse the impact of extreme weather events on their assets. This includes assessing physical asset damage, supply chain disruptions, operational downtime, and recovery costs. By comparing these metrics against historical data, companies can identify patterns and vulnerabilities. This analysis also reveals gaps in current data, highlighting areas where more information is needed to fully understand the impact. Including extreme weather events in CSRD reporting ensures your business acknowledges and prepares for the potential physical and financial ramifications of climate change.  

Traditionally, the focus of financial reporting revolved around the financial position and operations, such as assets, equities, and liabilities. This perspective was primarily inward-looking, concentrated on an organisation’s internal financial health.

The CSRD introduces a broader scope and longer horizon. The concept of Double Materiality necessitates institutions to consider factors that might not directly impact their balance sheets today but could do so in the future. This includes evaluating potential externalities, like environmental damage or societal impacts, which might translate into financial costs or liabilities down the road.

Moreover, there is a shift towards assessing how an organisation’s operations might influence the external world. This could be in the form of positive contributions, like community development initiatives, or negative impacts, like excessive carbon emissions. By acknowledging these broader factors, institutions provide a more holistic view of their position and potential trajectory in a rapidly evolving socio-economic landscape.

The CSRD, while challenging, presents a unique opportunity. Organisations can lead the way in transparency and sustainability by effectively leveraging short-term solutions. Would you like to know more or what ADC can do for you? Reach out to Fleur Fok (Project Lead) for a chat.