CSRD FY2025 Data Collection: Preparing for First Sustainability Reports

Organizations subject to the Corporate Sustainability Reporting Directive (CSRD) must prepare full sustainability disclosures aligned with European Sustainability Reporting Standards (ESRS). For organizations in the first wave of CSRD application, fiscal year 2025 represents the period for which sustainability data must be collected to support reports published in 2026. October 2025 marks a critical checkpoint for data collection processes, governance structures, and reporting capabilities.

CSRD application timeline and scope

The CSRD applies in phases based on organization size and characteristics. Large public-interest entities already subject to the Non-Financial Reporting Directive (NFRD) must report on FY2024 data in reports published in 2025. Large companies meeting two of three size thresholds (250+ employees, EUR 50M+ revenue, EUR 25M+ assets) must report on FY2025 data in reports published in 2026.

Subsequent phases extend CSRD requirements to listed SMEs (FY2026, with opt-out until FY2028) and certain non-EU companies with significant EU operations (FY2028). If you are affected, assess which phase applies to them and plan data collection as needed. Phase timing affects the urgency of current preparation activities.

Scope determination requires careful analysis of organizational structure, subsidiaries, and value chain relationships. CSRD reporting covers not just the reporting entity but material sustainability matters across the value chain. If you are affected, map their reporting boundaries and identify data sources across operations, suppliers, and downstream activities.

European Sustainability Reporting Standards overview

ESRS specify disclosure requirements across environmental, social, and governance topics. Cross-cutting standards (ESRS 1 and ESRS 2) establish general requirements and mandatory disclosures applicable to all reporting organizations. Topical standards cover specific sustainability matters including climate, pollution, biodiversity, workers, affected communities, and business conduct.

Materiality assessment determines which topical standards require full disclosure. Organizations must conduct double materiality assessment considering both impacts on sustainability matters (impact materiality) and sustainability matters' effects on the organization (financial materiality). Material topics require full disclosure; non-material topics require only brief explanation of the materiality assessment outcome.

Disclosure requirements include policies, actions, targets, and metrics for material topics. Organizations must explain their approach to managing sustainability matters, actions taken or planned, quantitative and qualitative performance indicators, and how sustainability matters relate to business model and strategy. Comparative information and forward-looking statements support stakeholder analysis.

Data collection requirements

ESRS metrics require data that many organizations have not historically collected with the rigor needed for external reporting. Climate-related disclosures require greenhouse gas emissions data across Scopes 1, 2, and 3, often demanding data from suppliers and value chain partners. Social metrics require workforce demographics, training hours, health and safety statistics, and supply chain labor practices information.

Data quality requirements for CSRD reporting are more stringent than for voluntary sustainability disclosures. Information must be auditable, with supporting documentation enabling third-party assurance. If you are affected, establish data governance processes that ensure accuracy, completeness, and traceability of sustainability information.

Value chain data presents particular challenges given limited control over third-party information. If you are affected, engage with key suppliers and customers to establish data sharing arrangements. Where primary data is unavailable, ESRS permits use of industry averages or estimates with appropriate disclosure of methodology and limitations.

Governance and accountability

CSRD requires that sustainability disclosures be approved by management bodies responsible for the management report in which they appear. Board and executive leadership must understand sustainability disclosures and take accountability for their accuracy. Governance structures should provide leadership visibility into sustainability performance and emerging issues.

Internal controls over sustainability reporting should parallel controls over financial reporting. If you are affected, establish clear responsibilities for data collection, review and approval processes, and documentation standards supporting auditability. Control deficiencies identified during the first reporting cycle should be remediated promptly.

Audit committee and board reporting should include sustainability matters alongside financial performance. Leadership needs regular updates on data collection progress, emerging issues, and compliance status. Escalation procedures should address material developments requiring leadership attention.

Technology and systems requirements

Sustainability data management often requires new systems or significant improvements to existing capabilities. If you are affected, assess whether current systems can support ESRS data collection, calculations, and reporting or whether investments in sustainability data platforms are needed. System setup timelines should allow for testing before year-end data collection deadlines.

Integration with existing enterprise systems—ERP, HR, supply chain management—can reduce manual data collection burdens and improve data quality. APIs and data feeds should be established to automate data flows where possible. Manual data collection processes should be documented with clear instructions and validation procedures.

Reporting capabilities should enable generation of ESRS-compliant disclosures in required formats. European Single Electronic Format (ESEF) requirements apply to CSRD disclosures within annual reports. If you are affected, verify that reporting tools support digital tagging requirements and connectivity with financial reporting systems.

Assurance preparation

CSRD requires third-party assurance of sustainability disclosures. Initial assurance requirements specify limited assurance, with transition to reasonable assurance over time. If you are affected, engage assurance providers early and understand their expectations for evidence and documentation supporting disclosed information.

Assurance readiness activities should include documentation review, process walkthroughs with internal audit, and identification of areas requiring strengthened controls or additional evidence. Early engagement with assurance providers can identify issues while there is time to address them before the reporting deadline.

Internal audit should assess sustainability reporting processes and controls, providing independent perspective on readiness and identifying improvement opportunities. Audit findings should inform remediation priorities and help management understand assurance risk areas.

October checkpoint activities

October 2025 represents a critical checkpoint for FY2025 data collection. If you are affected, assess data collection progress against full-year requirements and identify any gaps requiring accelerated attention. Process issues discovered late in the year may be difficult to remedy in time for reporting deadlines.

Data validation activities should confirm that collected information is complete, accurate, and consistent with ESRS requirements. Sample testing can identify systematic issues that would affect disclosure quality. Validation findings should drive corrective actions while data collection continues.

Stakeholder communication should provide updates on CSRD preparation progress to boards, audit committees, and other governance bodies. Leadership should understand compliance status, key risks, and resource needs for the remaining preparation period. External stakeholder communication may be appropriate to signal organizational commitment to sustainability transparency.

60-day priority list

• Complete or validate double materiality assessment determining applicable ESRS topic standards.
• Assess data collection progress against full-year requirements and identify gaps requiring attention.
• Establish or strengthen value chain data sharing arrangements with key suppliers and customers.
• Validate that technology systems support required data collection, calculation, and reporting capabilities.
• Engage with assurance providers to understand evidence requirements and timeline expectations.
• Brief leadership on CSRD preparation status, key risks, and resource needs.
• Conduct sample data validation to identify quality issues while collection continues.
• Document processes and controls supporting sustainability data collection and reporting.

Analysis summary

CSRD represents the most significant expansion of corporate sustainability reporting requirements globally. Organizations subject to the directive face significant preparation burdens, particularly those that have not previously invested in strong sustainability data management capabilities. The timeline for first reports leaves limited runway for organizations that have delayed preparation.

Data collection challenges will probably be greatest for value chain information where organizations have limited visibility and control. If you are affected, focus on engagement with key suppliers and customers to establish data sharing expectations. Where primary data remains unavailable, you should develop defensible estimation methodologies and clearly disclose limitations.

Recommended: treating CSRD compliance as a transformation opportunity rather than a compliance burden. The disciplines required for strong sustainability reporting—full data management, clear governance, regular stakeholder communication—improve organizational sustainability performance regardless of regulatory requirements. Organizations that build strong sustainability capabilities will be better positioned as stakeholder expectations for sustainability transparency continue increasing.