# CSRD Compliance Programme Reference ## Programme Templates, Checklists, and Implementation Guidance --- ## 1. CSRD Implementation Roadmap ### Phase 0 — Scoping (Months 1–2) - [ ] Confirm in-scope status: check size thresholds (employees, turnover, assets), listing status, PIE status - [ ] Determine first mandatory reporting year (FY 2024, 2025, 2026, or 2028) - [ ] Identify group structure: parent, subsidiaries; check if subsidiary can rely on group CSRD report - [ ] Assess non-EU company obligations if applicable (>€150M EU turnover) - [ ] Identify existing ESG reporting: GRI, TCFD, CDP, SASB, NFRD — baseline assessment ### Phase 1 — Foundation (Months 2–5) - [ ] Appoint CSRD project lead and cross-functional team (Finance, Legal, Sustainability, HR, Risk) - [ ] Establish governance: board/committee oversight of CSRD preparation - [ ] Engage external advisors: CSRD consultant, assurance provider (early engagement recommended) - [ ] Conduct preliminary Double Materiality Assessment (DMA) — identify material ESRS topics - [ ] Map existing disclosures to ESRS datapoints — identify gaps - [ ] Assess data availability across all material ESRS topics ### Phase 2 — Gap Assessment and Planning (Months 4–8) - [ ] Complete full DMA with stakeholder engagement - [ ] Document DMA methodology and outputs (ESRS 2 IRO-1 / SBM-3) - [ ] Conduct detailed gap assessment: required datapoints vs. data available - [ ] Assess value chain data collection feasibility for material topics - [ ] Evaluate IT/systems requirements: data collection, aggregation, reporting systems - [ ] Design data collection processes and assign ownership - [ ] Plan Scope 3 GHG emissions programme (if E1 material) - [ ] Engage assurance provider: agree scope, approach, timeline for limited assurance ### Phase 3 — Data Collection and Controls (Months 6–14) - [ ] Implement data collection processes for all material ESRS datapoints - [ ] Develop and implement internal controls over sustainability reporting - [ ] Establish data quality review and sign-off procedures - [ ] Collect and verify Scope 1, 2, 3 GHG emissions data - [ ] Collect workforce data (ESRS S1 datapoints) - [ ] Implement value chain data collection: supplier questionnaires, CDP, proxy data - [ ] Develop transition plan (ESRS E1-1) if climate is material - [ ] Conduct scenario analysis for climate risks/opportunities (ESRS E1-9) ### Phase 4 — Drafting and Assurance (Months 12–18 from first reporting year) - [ ] Draft CSRD disclosures for all material ESRS topics - [ ] Ensure dedicated section in management report (Accounting Directive Art. 19a) - [ ] Apply XBRL/iXBRL digital tagging to sustainability disclosures (ESEF taxonomy) - [ ] Internal review: legal, finance, sustainability, board review of disclosures - [ ] Engage assurance provider for limited assurance engagement - [ ] Respond to assurance queries and implement recommendations - [ ] Obtain assurance report - [ ] Board / supervisory body sign-off ### Phase 5 — Publication and Ongoing Compliance - [ ] Publish sustainability disclosures in annual report - [ ] File ESEF-tagged annual report with national registry - [ ] Update DMA annually - [ ] Track ESRS amendments and Commission guidance - [ ] Monitor Omnibus Package simplifications (post-2025 legislative changes) - [ ] Begin preparation for reasonable assurance (phased in post-2028) --- ## 2. CSRD Gap Assessment Template ### Instructions Complete this table after DMA. For each material ESRS topic, assess current data availability and identify gaps requiring action before first reporting year. | ESRS | Disclosure | Required Datapoint | Current State | Gap | Priority | Action Required | Owner | Target Date | |------|-----------|-------------------|--------------|-----|---------|----------------|-------|------------| | ESRS 2 | GOV-1 | Board sustainability oversight | Partial — board reviews ESG quarterly | Missing: expertise credentials, time spent | HIGH | Document board ESG discussion records; collect CV/bio data | Company Secretary | Q2 2025 | | ESRS 2 | GOV-3 | Sustainability in incentive schemes | No ESG KPIs in remuneration | Gap: no linkage | HIGH | Board Remuneration Committee to design ESG KPIs | CHRO + Board RemCo | Q1 2025 | | ESRS 2 | SBM-3 | DMA output — material IROs | DMA not conducted | Critical gap | CRITICAL | Conduct DMA with stakeholder engagement | Sustainability team | Q3 2024 | | E1 | E1-6 | Scope 1, 2, 3 GHG emissions | Scope 1+2 available; Scope 3 not measured | Scope 3 all 15 categories missing | CRITICAL | Implement Scope 3 measurement programme | Operations + Procurement | Q1 2025 | | E1 | E1-1 | Climate transition plan | No formal plan | Full gap | HIGH | Develop transition plan aligned with SBTi/Paris | CEO + Strategy | Q2 2025 | | S1 | S1-16 | Gender pay gap | Partial HR data | Missing: median pay by gender | HIGH | Commission pay analysis; align with EU Pay Transparency Dir. | CHRO | Q3 2025 | | S1 | S1-14 | LTIFR (lost time injury rate) | Available for own employees | Missing: contractor data | MEDIUM | Extend H&S data collection to contractors | EHS Manager | Q4 2025 | | G1 | G1-3 | Anti-corruption training coverage | 60% employees trained | Missing: updated coverage data; need >80% | MEDIUM | Run annual anti-corruption training campaign | Legal/Compliance | Q2 2025 | **Priority Definitions:** - **CRITICAL:** Legal requirement; cannot publish without this data - **HIGH:** Material gap; will result in qualified assurance if not resolved - **MEDIUM:** Gap exists; resolution improves quality but limited assurance achievable - **LOW:** Enhancement opportunity; not essential for first-year compliance --- ## 3. Data Collection Framework ### Governance Data (ESRS 2 GOV) | Datapoint | Data Source | Frequency | Owner | |-----------|------------|-----------|-------| | Board member sustainability expertise | Board CVs / biography | Annual | Company Secretary | | Board ESG agenda items / time spent | Board meeting minutes | Annual | Company Secretary | | ESG KPIs in executive remuneration | RemCo decisions / contracts | Annual | CHRO / Legal | | Due diligence process coverage | Procurement / Legal | Annual | Legal | ### Climate Data (ESRS E1) | Datapoint | Data Source | Frequency | Owner | |-----------|------------|-----------|-------| | Scope 1 emissions | Fuel consumption records, fleet data | Monthly → Annual | Facilities / Fleet | | Scope 2 (location-based) | Electricity invoices + IEA grid factors | Monthly → Annual | Finance / Facilities | | Scope 2 (market-based) | Energy certificates (RECs, GOs, PPAs) | Annual | Energy Procurement | | Scope 3 Cat. 1 (purchased goods) | Supplier spend × emission factors (EPA/ecoinvent) | Annual | Procurement | | Scope 3 Cat. 3 (fuel & energy) | Calculated from S1+S2 data | Annual | Facilities | | Scope 3 Cat. 6 (business travel) | Travel management system | Annual | HR / Travel | | Scope 3 Cat. 7 (commuting) | Employee survey / commuting patterns | Annual | HR | | Scope 3 Cat. 11 (product use) | Product emission factors + sales data | Annual | Product team | | Scope 3 Cat. 12 (end-of-life) | Waste management data + product specs | Annual | Product team | | Energy consumption total | All energy bills / smart metering | Monthly → Annual | Facilities | | Renewable energy share | Energy purchase contracts / guarantees of origin | Annual | Energy Procurement | ### Workforce Data (ESRS S1) | Datapoint | Data Source | Frequency | Owner | |-----------|------------|-----------|-------| | Headcount by gender / contract type | HRIS system | Monthly → Annual | HR | | Turnover rate | HRIS system | Annual | HR | | Gender pay gap (median) | Payroll system analysis | Annual | HR / Finance | | Collective bargaining coverage | HR records / legal | Annual | HR | | LTIFR, fatalities | EHS / incident management system | Monthly → Annual | EHS | | Training hours per employee | LMS (Learning Management System) | Annual | L&D | | Parental leave uptake | HR records | Annual | HR | | CEO pay ratio | Remuneration disclosures / payroll | Annual | Finance / HR | --- ## 4. Scope 3 GHG Emissions Programme ### Category Priority Matrix | Category | Typically Material? | Data Availability | Recommended Approach | |----------|-------------------|------------------|---------------------| | Cat. 1: Purchased goods & services | Yes (for most) | Low-Medium | Spend-based with EEIO factors → supplier surveys for key items | | Cat. 2: Capital goods | Medium | Medium | Asset registry × emission factors | | Cat. 3: Fuel & energy (upstream) | Yes | High | Calculate from S1+S2 using GHG Protocol factors | | Cat. 4: Upstream transport | Medium | Low | Tonne-km × emission factors; freight invoices | | Cat. 5: Waste in operations | Low-Medium | Medium | Waste management invoices | | Cat. 6: Business travel | Medium | High | Travel management system data | | Cat. 7: Employee commuting | Medium | Low | Annual employee survey | | Cat. 8: Upstream leased assets | Sector-specific | Medium | Lease registry | | Cat. 9: Downstream transport | Sector-specific | Low | Distribution data | | Cat. 10: Processing of sold products | Sector-specific | Low | Industry averages | | Cat. 11: Use of sold products | Yes (for manufacturers) | Medium-High | Product emission factors × sales volume | | Cat. 12: End-of-life treatment | Medium | Low | Industry averages; waste composition | | Cat. 13: Downstream leased assets | Sector-specific | Low | Lease register | | Cat. 14: Franchises | Sector-specific | Low | Franchise data collection | | Cat. 15: Investments | Sector-specific (financial) | Medium | PCAF methodology | **Recommended Scope 3 Phasing:** - **Year 1:** Cats. 1, 3, 6, 7, 11 (typically 80%+ of emissions) - **Year 2:** Add Cats. 2, 4, 5, 12 - **Year 3:** Full coverage with improved primary data --- ## 5. Assurance Readiness Checklist ### Pre-Assurance Requirements **Governance and Responsibility** - [ ] Named individual responsible for each material ESRS topic and its data - [ ] Clear escalation path for sustainability data queries - [ ] Board/audit committee oversight of sustainability reporting **Documentation** - [ ] DMA documented with methodology, scoring, stakeholder inputs - [ ] Data collection procedures documented for each datapoint - [ ] Calculation methodology documented (GHG Protocol, ESRS guidance) - [ ] Internal review and sign-off process documented - [ ] Correction procedure for sustainability data errors **Data Quality** - [ ] Data trail from source system to reported figure for each datapoint - [ ] Evidence of data completeness checks (coverage of operations) - [ ] Prior year comparatives available and reconciled - [ ] Estimation methodology documented for gaps (proxy data, interpolation) - [ ] Restatement policy defined **Controls** - [ ] Internal controls documented for key sustainability data processes - [ ] Evidence of management review and approval of sustainability disclosures - [ ] Segregation of duties between data collectors and approvers **Boundary and Scope** - [ ] Reporting boundary clearly defined (consolidation approach: financial control, operational control, equity share) - [ ] Any boundary differences vs. financial reporting documented and justified - [ ] Value chain scope clearly defined and disclosed ### Limited Assurance vs. Reasonable Assurance | Aspect | Limited Assurance (Current) | Reasonable Assurance (Future) | |--------|----------------------------|------------------------------| | Standard | ISAE 3000 (Revised) | ISAE 3000 (Revised) — higher standard | | Procedures | Inquiries + analytical procedures | As above + substantive testing | | Evidence | Less extensive | More extensive; site visits typical | | Conclusion | "Nothing came to our attention" | "The information is fairly presented" | | Documentation | Less detailed | Detailed audit-like evidence file | | Timeline | CSRD Phase 1 (now) | Commission review by 2028 | **Practical Tip:** Build reasonable assurance-quality documentation from day one — retroactively improving evidence trails is very difficult and expensive. --- ## 6. XBRL Digital Tagging — Practical Guide ### What Must Be Tagged - All quantitative datapoints in the sustainability disclosures - Key qualitative disclosures (policy statements, targets) - Taxonomy: European Single Electronic Format (ESEF) extended with CSRD sustainability taxonomy ### Tagging Approach Options 1. **Software-integrated:** Sustainability reporting software with built-in XBRL tagging (SAP Sustainability Footprint Management, Workiva, Sweep, etc.) 2. **Post-report tagging:** Tag the final report using ESEF tagging tools 3. **Outsourced:** Use XBRL tagging service provider ### Timeline - ESEF sustainability taxonomy: Commission in development (consult ESMA for latest timeline) - First XBRL-tagged sustainability reports: aligned with first CSRD reporting year --- ## 7. Value Chain Data Collection — Supplier Engagement ### Supplier Prioritisation Framework Prioritise suppliers based on: 1. **Spend-based emissions significance** (Cat. 1 Scope 3 contribution) 2. **High-risk sectors** (garments, electronics, agriculture, extractives) 3. **High-risk geographies** (countries with elevated labour/environmental risks) 4. **Strategic / sole-source relationships** (limited substitutability) ### Data Collection Methods | Method | Best for | Effort | Data Quality | |--------|---------|--------|-------------| | CDP Supply Chain | Large, listed suppliers | Low (for company) | High | | Supplier questionnaire (EcoVadis, custom) | Tier-1 suppliers | Medium | Medium-High | | Spend-based emission factors (EEIO) | Long-tail suppliers | Very low | Low-Medium | | Industry sector averages | Where direct data unavailable | Very low | Low | | Site audits | High-risk suppliers | High | Very High | ### Disclosure of Estimation Approaches (ESRS 1, para. 64) Where value chain data is not directly available, companies must disclose: - Which datapoints use estimated/proxy data - The estimation methodology applied - The level of accuracy and main sources of uncertainty - Steps being taken to improve data quality over time --- ## 8. CSRD vs. NFRD — Key Differences | Aspect | NFRD (old) | CSRD (new) | |--------|-----------|-----------| | Companies in scope | ~11,000 (PIEs >500 employees) | ~50,000 (all large + listed SMEs) | | Non-EU companies | Not covered | >€150M EU turnover | | Standards | No mandatory standards | Mandatory ESRS | | Materiality | Financial only | Double materiality (impact + financial) | | Value chain | Not required | Required where material | | Assurance | Not required (some member states) | Mandatory limited assurance | | Digital tagging | Not required | XBRL/iXBRL mandatory | | Location | Flexible (separate report allowed) | Dedicated section of management report | --- ## 9. Omnibus Package Watch (2025) The European Commission proposed CSRD simplifications in the "Omnibus Package" (February 2025): **Proposed changes (not yet final as of ESRS publication date):** - Narrowing scope: may raise employee threshold to 1,000 (from 250) - Reducing mandatory datapoints - Delaying listed SME obligations - Simplifying value chain reporting requirements **Important:** Always verify the current legislative status before advising clients on scope and datapoint requirements. Check EUR-Lex and the European Commission website for latest developments. The underlying ESRS standards issued under Commission Delegated Regulation (EU) 2023/2772 remain the definitive source until amended.