Currently, hardly a day goes by without companies and their employees being confronted with the topic of sustainability, one way or the other. Especially the requirement of sustainability reporting is of high relevance for many teams and business units. In this context not only the multitude of acronyms such as CSRD, ESG, ESRS and their meaning is posing a challenge, but above all the complexity of the many topics and tasks makes it difficult to begin the process of developing a sustainability report in line with the new legal requirements.
In order to support companies in fulfilling their reporting obligations, the European Commission has published the European Sustainability Reporting Standards (ESRS). The use of the standards is required for the reporting under the Corporate Sustainability Reporting Directive (CSRD). With almost 250 pages (not including the sector-specific standards), it is fair to question to what extent the ESRS clarify or ease the process of reporting, However, the ESRS put the “double materiality assessment” at the core of the CSRD report and define it as the starting point for the reporting process. Both, the financial as well as the impact level need to be considered during the assessment and a detailed analysis of impacts, risks and opportunities must be performed.
However, the exact procedure of the materiality assessment must be individually tailored to the company in question; a “one size fits all” model cannot be applied. Depending on the company-specific situation, for example due to previous reporting requirements under the Non-Financial Reporting Directive, existing processes and data may be used and adapted to the new requirements. Generally speaking, in a first step, scanning the ESRS topics and collecting relevant issues will provide the basis for, in a second step, stakeholder involvement in order to identify and verify topics to be addressed in the process of compiling the report. Topics identified as “material“ need to be included in the report and will define the four sections of the report: “general information”, “environmental information”, “social information” and “governance information”. The sustainability declaration must be included in the management report.
In our view, the introduction of the ESRS brings the structure and content of the sustainability declaration onto a common level for all obligated companies. Still, a lot of freedom remains, especially with regard to the approach and process of creating the report. On the one hand this flexibility offers the opportunity to address a company’s individual situation, but, on the other hand makes the number of tasks to be completed appear rather large and unstructured.
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