Policy Briefing — October 12, 2025
Large EU companies subject to the Corporate Sustainability Reporting Directive must close Q3 data gaps now to deliver FY2025 CSRD reports, the first cycle for entities newly in scope beyond the former NFRD population.
Executive briefing: Corporate Sustainability Reporting Directive (CSRD) obligations expanded on 1 January 2025 to cover large EU companies that meet two of three criteria (250 employees, €40 million turnover, €20 million balance sheet). These companies will publish their first ESRS-compliant sustainability statements in 2026 for the 2025 financial year. By October, data leaders must confirm coverage of all 12 ESRS standards, reconcile taxonomy tags, and evidence double materiality assessments.
Key data-management checkpoints
- Double materiality validation. Document stakeholder engagement, impact assessments, and financial materiality scoring that justify topic inclusion or omission in ESRS disclosures.
- Data lineage. Map each ESRS datapoint to source systems (ERP, HCM, EHS, procurement) and capture controls, sign-offs, and audit trails.
- Taxonomy tagging. Align reported metrics with the European Single Electronic Format (ESEF) taxonomy and ensure XBRL tagging is tested before FY close.
Operational priorities
- Assurance readiness. Coordinate with statutory auditors on limited assurance procedures, ensuring evidence folders meet ISAE 3000 requirements.
- Value chain data. Collect Scope 3 and upstream/downstream impact data, documenting estimation methodologies and supplier engagement.
- Governance cadence. Establish quarterly sustainability steering committees to review KPIs, remediation plans, and narrative drafts.
Enablement moves
- Deploy CSRD data models within data warehouses or ESG platforms to centralize metrics and controls.
- Run dry-run filings to test ESEF submissions, auditor collaboration, and board approval workflows before the 2026 filing window.
Sources
Zeph Tech operationalizes CSRD data collection by unifying ESRS data models, assurance evidence, and ESEF tagging workflows.
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