CSRD application in 2025 for 2026 reporting - process, common pitfalls & advice

In this article, we'll make sure you know everything you need to know and provide a step-by-step guide to achieve compliance in time.

Key points that will be covered: 

• Brief overview of CSRD & requirements
• Importance of preparation before getting started
• Step by step process to be compliant with CSRD
• Common pitfalls when implementing CSRD
• Get inspired by our clients

A brief overview of the CSRD and its requirements

In short, the CSRD is the European Union directive designed to increase transparency and accountability in sustainability reporting. It requires companies to disclose information on their environmental, social, and governance (ESG) performance. CSRD is the most ambitious regulation ever introduced in the field of sustainability demanding new data-driven efforts from companies.

There are different application dates for companies subject to this reporting based on their size & financial metrics. If you have a doubt by when you need to comply, reach out to our team of expert:

For which companies does the CSRD apply for the fiscal year 2025, with the first report due in 2026?

This timeline applies to your company if you answer "yes" to at least two of the following questions:

• Does your company employ more than 250 people?
• Is the turnover €50 million or more?
• Are the total assets worth €25 million or more?

⏰ To ensure you can submit an auditable report by 2026, you'll need to start collecting the necessary metrics beginning in January 2025 ⏰

Why not getting ready in time is dangerous

First reports are due in 2026, so you may wonder why companies are working so hard to be ready by January 2025. The answer lies in the goals of the CSRD. When drafting the directive, the EFRAG aimed to increase the reliability of ESG data: it must become as reliable and accurate as financial information. This has several implications, such as ensuring the audit trail of every piece of data. For a specific data point, you should be able to:

• Prove that the information source is reliable.
• Track and log every update of the data point.
• Define a person responsible for each data point (data owner).

Note that external auditors should reach the same conclusions as you. Consequently, if you must report in 2026 on 2025 data, your company should have the systems in place to collect audit-proof data as of the beginning of your 2025 fiscal year - meaning January for most companies. 

Risks of Delaying the Data Capture Process

If you start the data capture process later, you will face two types of risks:

• Missing Data: If you don't conduct a thorough data mapping before 2025, you may miss important data points that will be difficult to obtain later.
• Breaking the Audit Trail: Similar to financial statements, auditors need to be able to trace and access all ESG data points relevant to the audited year. Inadequate data capture can compromise the audit process.

Getting ready: A Step-by-Step guide

It may seem obvious, but the first step is dedicating time to familiarize yourself with the CSRD requirements, scope, and timeline. The EFRAG website and our articles are good places to start.

You can run the entire project on your own or with the support of a partner. At ROSE, we assist our clients with all the following steps during the software implementation phase. Our methodology aligns with EFRAG's guidance: 

Step 1: Perform the Double Materiality Assessment in 4 phases

The Double Materiality Assessment (DMA) is a critical step that may seem complex at first but is manageable with the right methodology.

Phase 1: Perform the value chain & stakeholders mapping 

Value chain mapping is about identifying and visualizing the key activities, processes, and stakeholders involved in creating and delivering a product or service. Here are the main steps. 

• A division by business areas is made.
• Each activity involved at a specific point in the value chain (downstream, upstream, on operation) is reviewed.
• Dependencies & affected stakeholders can be described as well.

For the stakeholder mapping, there are two main types: those affected by the impacts and those who will use the sustainability reports. We recommend mapping the existing interactions that your company already has with them (a classic is exisiting employee survey) and the related expectations that are already clear from those. This will form a basis to then understand where stakeholder involvement is missing and will be most needed.

Phase 2: Impact, Risk, Opportunities (IROs)

It involves determining what is material for your company and, therefore, what elements are mandatory for your CSRD report. During this process, we list the company's impacts (positive and negative), risks, and opportunities (IROs) related to the sustainability matters (topics, sub-topics and sub-sub-topics). This is an extensive process which is further describe into this article.

Phase 3: Setting Thresholds & Scoring

In this phase, the company defines whether each IRO is considered material or not. 

• Only elements exceeding certain thresholds will be material and applicable to your company.
• A formula considering factors like scale, scope, remediability, and likelihood defines these thresholds.
• When a score exceeds the threshold, the topic is material, and applicable data points are then identified for reporting.

Based on the material IROs, the final list of material sustainability matters (topics, sub-topics and sub-sub-topics) is narrowed down.

Phase 4: From sustainability matters to disclosure requirements

Once the sustainability matters have been identified, the final step will be to define the disclosure requirements deriving from sustainability matters.

Step 2: Retrieve and manage data

To comply with CSRD, companies must collect data on identified disclosure requirements and include this information in their sustainability reports.

In our experience, this step is the biggest challenge due to the sustainability data complexity:  

• Holistic nature: Data covers environmental, governance, and social aspects, involving diverse metrics such as tons, cubic meters, gender gaps, or written policies.
• Scattered data: Sustainability data is stored in various places—accounting software, HR suites, ERPs, payrolls, or even local sensors in the field. Retrieving and managing this data takes time.
• Data quality: After retrieving data, ensuring its quality, consistency, and completeness is key.

Proper data management is essential at every stage of sustainability management: becoming CSRD compliant, setting achievable goals, and making business decisions based on sustainability impacts.

Note: At ROSE, we simplify this process using the data studio, a dedicated part of our software that allows you to upload source files from different source systems and work on the data in one place.

Step 3: Define goals and targets

A common mistake is thinking the job is done after addressing the data gathering. CSRD goes beyond previous regulations, requiring companies to set goals and prove continuous improvement.

• Alignment: Goals should align with your materiality assessment and the EU taxonomy.
• Ownership: Goals should be assigned to a specific person (owner), held accountable for the progress, making sure that the work is coordinatedand ensuring deadlines are met.
• Action steps: Break down goals into smaller actions, each with its owner and deadline.

Note: Using dedicated software for managing goals and actions is not mandatory but helpful, as all of it needs to be consolidated into the report. ROSE offers this feature.

Step 4: Start drafting your first CSRD aligned report 🎉

If you've followed the previous steps, this last part should be straightforward. However, there are still a few things to consider:

• Report structure: Ensure it aligns with CSRD requirements.
• Readability: Reports must be readable by both humans and machines, so keep them concise and clear, and include XBRL tags.‍
• Real-Time updates: Ideally, use a tool that allows you to create multiple templates and update data in real time. This will enable you to track progress and provide information to internal and external stakeholders (e.g., communication and marketing departments, clients, suppliers).

Common pitfalls and how to avoid them

Here are the most common pitfalls we've identified and suggestions on how to avoid them.

➡️ Trying to do everything on your own: The CSRD is an unprecedented regulation on the sustainability topic. It is ambitious and involves a certain degree of complexity. At least for the first year, it is a good idea to be helped by CSRD experts, whether they come from consultancy or software companies. 

➡️ Over-relying on consultancy: From an extreme to another! Some companies may over-rely on external expertise instead of building internal skills. Balance is key. External expertise can be valuable, but building internal skills is crucial to avoid unpredictable costs as regulations become more complex.

➡️ Underestimating the data topic: The data topic is often the biggest challenge. Dedicate time to understanding where every piece of data is stored, how to retrieve it properly, clean it, and ensure its reliability. Involve your IT department if necessary.

➡️ Trying to automate everything: Not everything needs to be automated. The key to identify what should be automated first is the update frequency. If a data point needs to be updated every day or every week, it probably needs to be automated. If the frequency is quarterly or yearly, probably not. 

➡️ Forgetting about the audit trail: Ensure that every data point has a dedicated owner, logs of every update, and explanations for any assumptions made. Remember that an external auditor should reach the same conclusions than yours

➡️ Forgetting about continuous improvement: The CSRD isn't just a static picture of your sustainability practices—it's about proving continuous improvement. Set goals, break them down into actions, and involve everyone.

➡️ Considering this exercise only from a compliance perspective: CSRD is a tremendous opportunity to generate value and gain advantages over your competitors, as every stakeholder (clients, suppliers) are asking for more sustainability commitments.

➡️ Solely using excel: You must be equipped with a dedicated sustainability management software. It may sound like self-interested advice, but the software does not even have to be ROSE. The alternative of having a dedicated tool is generally using Excel, which leads to breaking the audit trail and generating mistakes due to manual entries and multiple file versions shared among stakeholders.
Make sure to choose a software that guarantees at least the following:

• Ability to import source files from your information systems and manipulate the data into the platform. Note: without using templates!! That would be missing the point.
• Goals and actions management feature imbedded in the platform 
• Unlimited template creation for reports and updates in real time

Get Inspired: read about companies preparing for CSRD compliance and sustainability improvement

It's always valuable to learn from companies facing similar challenges. At ROSE, we're fortunate to support businesses across various industries. Here are a few examples:

• Italdesign (Automotive design and mobility industry): Discover how they're focusing on data to make ESG data as reliable as the financial one.
• Bolsius (Europe's largest candle manufacturer): See how they are future-proofing their ambitious sustainability strategy by centralizing all ESG topics in one hub.
• Vroon (Leading international shipping company): Learn how they are leveraging ROSE at every step, from DMA to continuous improvement.
  
  ✉️ Do you have a comment, suggestion, or question? We'd love to hear from you. Feel free to contact us here.