CSRD and ESRS E1: the data requirements of climate reporting

The Corporate Sustainability Reporting Directive (CSRD) puts sustainability information under the same regime as financial information: in the same report, under the same management responsibility, with independent assurance. The implementation detail sits in the European Sustainability Reporting Standards (ESRS), and climate is standard E1.

Double materiality

The core concept in ESRS is double materiality. A topic can be material in two ways: if the company’s impact on it is significant (impact materiality), or if it affects the company’s financial position (financial materiality). Either is enough. In practice climate passes both tests in almost every sector.

The materiality assessment itself is reported: which topics were deemed material and why, which stakeholders were consulted and how, and the method used. That is the mechanism preventing arbitrary narrowing of scope.

What E1 requires

• Scope 1, 2 and 3 emissions — Scope 3 cannot be excluded without demonstrating immateriality
• Both location-based and market-based figures for Scope 2
• Total greenhouse gas emissions and intensity per unit of revenue
• Energy consumption and mix, including the renewable share
• A climate transition plan — with its basis, where alignment with 1.5 °C is claimed
• Short, medium and long-term abatement targets and the base year
• Financial effects of climate change and exposure to physical risk

The hardest line on that list is Scope 3. Under earlier voluntary regimes Scope 3 was usually partial and missing categories were quietly skipped. ESRS closes that door: excluding a category requires demonstrating that it is immaterial.

Why companies outside scope are still affected

CSRD directly covers only companies above certain size thresholds. But those companies’ Scope 3 data comes from their suppliers. A Turkish producer selling to a European customer will face product-level emissions data requests because of the customer’s reporting obligation, even if they are not in scope themselves.

In practice the request arrives not as a questionnaire but as a field in a supplier portal: kg CO₂e per product, verification status, data source. A supplier who cannot fill those fields is represented by average data in the customer’s report — and average data is usually worse than actual performance.

Data infrastructure: the invisible part of the report

An ESRS report is subject to independent assurance, which means the data path behind the figures is audited. That requires sustainability data to be managed like financial data: source documents, calculation steps, approval records and versioning. A dataset assembled in spreadsheets at year-end does not pass that audit.