Deliver verifiable sustainability reporting for energy-intensive infrastructure

Understand the evolving regulatory landscape

CSRD expands reporting obligations to over 50,000 EU companies and non-EU entities with significant EU operations. The first set of ESRS standards, adopted by the European Commission in July 2023, includes cross-cutting requirements (ESRS 1 and 2) and topical standards covering climate (E1), pollution (E2), water and marine resources (E3), biodiversity (E4), resource use and circular economy (E5), and social topics.^{European Commission CSRD resourcesESRS Delegated Act Annex 1} Operators must perform double materiality assessments that consider financial materiality and impact materiality.

Beyond the EU, jurisdictions adopt their own frameworks. The UK’s Transition Plan Taskforce (TPT) published sector-neutral disclosure framework guidance in 2023, and the Financial Conduct Authority expects listed companies to reference it in climate transition plans.^{TPT Disclosure Framework} Japan’s Financial Services Agency updated its Corporate Governance Code to include sustainability disclosures, and Singapore’s SGX requires climate reporting aligned with TCFD for issuers in energy, finance, agriculture, and shipping sectors.^{Japan FSA Corporate Governance CodeSGX Sustainability Reporting}

In North America, the U.S. Securities and Exchange Commission finalised a climate disclosure rule in March 2024, requiring large registrants to report Scope 1 and Scope 2 emissions, climate risk governance, and material financial impacts.^{SEC Climate Disclosure Rule} California’s Climate Corporate Data Accountability Act (SB 253) and Climate-Related Financial Risk Act (SB 261) extend reporting to private companies with revenues above $1 billion.^{California SB 253California SB 261} Canada mandates climate disclosures for federally regulated financial institutions via the Office of the Superintendent of Financial Institutions (OSFI) Guideline B-15.^{OSFI Guideline B-15}

Other jurisdictions are converging on global baselines. Brazil’s securities regulator (CVM) issued Resolution 193 in October 2023, requiring listed companies to adopt IFRS S1 and IFRS S2 disclosures from 2026 onwards, with voluntary adoption encouraged earlier.^{CVM Resolution 193} South Africa’s Johannesburg Stock Exchange released Sustainability and Climate Disclosure Guidance aligned to TCFD and GRI to support issuers and institutional investors.^{JSE Sustainability Disclosure Guidance} ASEAN finance ministers endorsed Version 2 of the ASEAN Taxonomy for Sustainable Finance, which introduces science-based criteria for classifying transition activities relevant to energy, transport, and industrial infrastructure.^{ASEAN Taxonomy Version 2}

Establish governance, ownership, and controls

Robust governance underpins credible sustainability reporting. Boards must oversee sustainability strategy, risk management, and disclosure quality. The World Economic Forum’s “Stakeholder Governance Metrics” recommend board-level oversight of climate and sustainability performance, while the Institute of Internal Auditors’ (IIA) guidance emphasises assurance planning for ESG data.^{WEF Stakeholder Capitalism MetricsIIA ESG Guidance}

Create a sustainability steering committee that includes finance, legal, operations, procurement, and IT. Define roles and responsibilities using RACI matrices, and align with COSO’s “Internal Control over Sustainability Reporting” (ICSR) guidance released in 2023.^{COSO Internal Control over Sustainability Reporting} Embed sustainability KPIs into executive compensation and management scorecards, referencing Zeph Tech’s board oversight guide.

Implement disclosure controls and procedures similar to financial reporting. Establish documentation standards, version control, and segregation of duties for sustainability data. Leverage internal audit to test controls and ensure alignment with assurance standards such as the International Auditing and Assurance Standards Board’s (IAASB) proposed International Standard on Sustainability Assurance (ISSA) 5000.^{IAASB ISSA 5000 Exposure Draft}

Build data architecture and quality management

Sustainability reporting depends on accurate, granular data. Develop a data architecture that ingests operational data (energy use, fuel consumption, water, waste), supply chain metrics, and financial information. Adopt ISO 14064-1 for greenhouse gas inventory quantification and ISO 50001 for energy management systems to ensure consistent measurement.^{ISO 14064-1:2018ISO 50001}

Implement data governance processes aligned with DAMA-DMBOK and leverage data catalogues to track lineage, ownership, and transformation logic. Integrate data quality checks referencing Zeph Tech’s data quality assurance guide, focusing on completeness, accuracy, timeliness, and auditability.

Digitise meter readings and facility telemetry. Deploy building management systems, IoT sensors, and automated meter reading (AMR) to collect high-frequency energy and water data. Follow the U.S. Department of Energy’s “Federal Energy Management Program (FEMP) Measurement and Verification Guidelines” for metering and verification best practices.^{DOE FEMP M&V Guidelines} Ensure cybersecurity controls protect data integrity by aligning with NIST SP 800-82 for industrial control systems.

For Scope 3 emissions, map upstream and downstream value chain activities using the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Standard and the Science Based Targets initiative (SBTi) guidance for ICT and telecom sectors.^{GHG Protocol Scope 3 StandardSBTi ICT Guidance} Prioritise high-impact categories such as purchased goods and services, capital goods, fuel- and energy-related activities, and use of sold products.

Define metrics, targets, and scenarios

Metrics must satisfy regulatory standards and stakeholder expectations. ESRS E1 requires disclosure of Scope 1, Scope 2, and relevant Scope 3 greenhouse gas emissions, energy consumption, energy mix, and carbon intensity. IFRS S2 mandates disclosure of climate-related targets, metrics, and transition plans, aligning with the Task Force on Climate-related Financial Disclosures (TCFD) pillars.^{IFRS S2 Climate-related Disclosures}

Establish science-based targets consistent with the Paris Agreement. Use SBTi sectoral decarbonisation approaches or absolute contraction methods to set reduction trajectories. Document target boundaries, base years, and progress, explaining deviations and corrective actions.

Scenario analysis is essential. Use the Network for Greening the Financial System (NGFS) climate scenarios, the International Energy Agency’s (IEA) Net Zero Emissions by 2050 Scenario, and IRENA’s World Energy Transitions Outlook to stress-test business models.^{NGFS Climate ScenariosIEA Net Zero by 2050IRENA World Energy Transitions Outlook} Document assumptions, modelling tools, and sensitivity analyses. Tie results to capital allocation, insurance coverage, and resilience investments described in Zeph Tech’s infrastructure resilience guide.

Complement climate metrics with resource and social indicators. Track water withdrawal and discharge using the Alliance for Water Stewardship (AWS) Standard, waste and recycling per ESRS E5, and occupational health metrics aligned with ISO 45001.^{Alliance for Water Stewardship StandardISO 45001}

Investors also compare performance using the Sustainability Accounting Standards Board (SASB) Infrastructure and Telecommunications standards, which specify metrics such as energy consumption of network traffic, percentage of renewable energy, and resilience investments.^{SASB Standards} Map SASB disclosures to ESRS datapoints to ensure consistency and avoid duplicate reporting.

Leverage sector benchmarks and frameworks

Infrastructure sectors benefit from specialised benchmarks. Data centres can align with the European Code of Conduct on Data Centre Energy Efficiency, Uptime Institute’s Sustainability Reporting 2023 guidelines, and ENERGY STAR for Data Centers certification.^{EU Code of Conduct for Data CentresUptime Institute Sustainability Reporting 2023ENERGY STAR Data Centers}

Telecom operators can use the GSMA Net Zero Tracker, ITU-T L.1470 energy efficiency methodologies, and ETSI ES 202 706 carbon footprint assessments for ICT goods and networks.^{GSMA Net Zero TrackerITU-T L.1470ETSI ES 202 706}

Energy utilities must align with the Edison Electric Institute (EEI)/American Gas Association (AGA) ESG reporting templates, the Taskforce on Nature-related Financial Disclosures (TNFD) beta framework, and the World Resources Institute’s Aqueduct water risk tool.^{EEI-AGA ESG TemplateTNFD FrameworkWRI Aqueduct}

Transportation infrastructure, including airports and ports, can reference the Airport Carbon Accreditation program, the International Maritime Organization’s (IMO) Carbon Intensity Indicator (CII) requirements, and the Global Logistics Emissions Council (GLEC) framework for freight emissions.^{Airport Carbon AccreditationIMO Carbon Intensity IndicatorGLEC Framework}

Deploy technology to enable reporting

Technology platforms reduce manual effort and improve auditability. Evaluate carbon accounting software that supports GHG Protocol calculations, emission factor management, and workflow approvals. Gartner’s 2024 Market Guide for ESG Management and Reporting Systems profiles vendors with robust security, integration, and assurance capabilities.^{Gartner Market Guide for ESG Management Systems}

Integrate sustainability platforms with enterprise resource planning (ERP), energy management, and procurement systems via APIs. Adopt data exchange standards such as the Sustainability Accounting Standards Board (SASB) XBRL taxonomy and the CDP reporting schema to automate external submissions.^{SASB XBRL TaxonomyCDP Reporting Guidance}

Use workflow automation to manage data requests, approvals, and sign-offs. Implement identity and access management consistent with ISO/IEC 27001 to ensure only authorised personnel can modify sustainability data. Embed digital signatures to maintain traceability.

Leverage analytics and dashboards to communicate progress. Tools like the Global Reporting Initiative’s (GRI) Disclosure Database and the World Business Council for Sustainable Development’s (WBCSD) Reporting Exchange offer peer comparisons.^{GRI Reporting ResourcesWBCSD Reporting Exchange}

Participate in industry data-sharing initiatives such as the OpenFootprint Forum under the Joint Development Foundation, which is building an open standard for emissions accounting APIs, and the Partnership for Carbon Accounting Financials (PCAF) for financed emissions methodologies applicable to infrastructure lenders.^{OpenFootprint ForumPCAF}

Prepare for assurance and attestation

CSRD requires limited assurance on sustainability information, with a transition to reasonable assurance envisaged. Engage assurance providers early to validate scope, materiality determinations, and internal controls. Align methodologies with ISAE 3000 (Revised) and upcoming ISSA 5000 standards.^{ISAE 3000 (Revised)}

Document data trails, including source systems, calculation methodologies, adjustment logs, and management review notes. Use secure data rooms to share evidence with auditors, maintaining access logs for accountability. Coordinate with internal audit to perform readiness assessments and remediate control gaps before external assurance begins.

For greenhouse gas inventories, ensure third-party verification meets ISO 14064-3 requirements, and consider accreditation under ISO 14065 for validation and verification bodies.^{ISO 14064-3ISO 14065} Maintain documentation for emissions factors, meter calibrations, and sampling methodologies.

Craft narratives and multi-channel reporting

Effective sustainability reports combine quantitative data with compelling narratives. Structure disclosures around TCFD pillars (governance, strategy, risk management, metrics and targets) and ESRS architecture. Provide cross-references to annual reports, integrated reports, and investor presentations to ensure consistency.

Leverage the Climate Disclosure Standards Board (CDSB) application guidance to translate TCFD principles into decision-useful narratives and data tables, ensuring consistency across financial filings and sustainability reports.^{CDSB Application Guidance} The guidance includes sectoral examples for utilities, transportation, and technology operators that mirror infrastructure portfolios.

Tailor messaging for stakeholders. Investors want clarity on capital allocation, resilience investments, and profitability impacts; regulators focus on compliance and risk mitigation; customers expect supply chain transparency; employees look for progress on diversity, safety, and community engagement.

Publish machine-readable data through XBRL filings and APIs where required. The European Single Electronic Format (ESEF) taxonomy extends XBRL tagging to sustainability data under CSRD.^{ESMA ESEF} Maintain version-controlled repositories for published reports, investor decks, and supporting appendices.

Coordinate communications across departments. Align press releases, web content, and investor calls to avoid contradictory statements. Use Zeph Tech’s board oversight guide for briefing templates and oversight checklists.

Engage stakeholders and integrate feedback

Stakeholder engagement is central to double materiality. Map stakeholders—investors, customers, employees, regulators, community groups, suppliers—and develop engagement plans with frequency, format, and documentation requirements. The Global Reporting Initiative’s GRI 2 standard mandates disclosure of stakeholder engagement processes.^{GRI 2 General Disclosures}

Adhere to the 2023 update of the OECD Guidelines for Multinational Enterprises, which emphasises responsible business conduct, grievance mechanisms, and climate disclosures across infrastructure supply chains.^{OECD Guidelines for Multinational Enterprises} Embed these expectations into supplier codes of conduct and contract clauses.

Collect feedback through surveys, town halls, advisory panels, and customer scorecards. Integrate insights into risk registers, product development, and capital allocation. Document how stakeholder input informs materiality, targets, and strategy.

For infrastructure projects, conduct environmental and social impact assessments (ESIA) that comply with the International Finance Corporation’s (IFC) Performance Standards. Engage communities early to address concerns about land use, biodiversity, noise, and emissions.^{IFC Performance Standards}

Integrate sustainability with capital planning and risk

Sustainability reporting should influence capital allocation. Integrate climate risk findings into enterprise risk management frameworks (ISO 31000) and align with financial planning and analysis (FP&A) cycles. The European Investment Bank’s (EIB) Paris Alignment framework and the Principles for Responsible Investment (PRI) offer guidance on incorporating climate considerations into investment decisions.^{EIB Climate Bank RoadmapPRI Climate Guidance}

Infrastructure finance teams can also draw on the UN-convened Net-Zero Asset Owner Alliance Target Setting Protocol to understand investor expectations for interim emission reductions and portfolio alignment.^{Net-Zero Asset Owner Alliance Protocol} Incorporate these thresholds into treasury policies, green bond frameworks, and sustainability-linked loan covenants.

Develop internal carbon pricing to guide project prioritisation. The World Bank’s “State and Trends of Carbon Pricing 2024” documents prevailing carbon prices and corporate practices.^{World Bank Carbon Pricing Dashboard} Use scenario analysis outputs to stress-test investment returns and update hurdle rates.

Align insurance and resilience investments with climate risk findings. Reference the Insurance Europe position on climate resilience and the U.S. Federal Insurance Office’s climate-related financial risk report to understand underwriting expectations.^{Insurance Europe Climate ResilienceU.S. Federal Insurance Office Climate Report}

Drive continuous improvement and culture change

Sustainability reporting is iterative. Establish continuous improvement cycles that include quarterly performance reviews, annual materiality refreshes, and updates to policies and procedures. Implement training programmes for finance, engineering, and operations teams on measurement protocols, reporting systems, and regulatory changes.

Embed sustainability into procurement by referencing ISO 20400 for sustainable procurement and requiring suppliers to disclose emissions and ESG metrics.^{ISO 20400} Collaborate with suppliers through initiatives like the Responsible Business Alliance (RBA) or CDP Supply Chain to improve data quality and performance.

Use innovation programmes to pilot low-carbon technologies, circular economy initiatives, and nature-positive solutions. Track outcomes and integrate successful pilots into standard operations.

Roadmap for sustainability reporting maturity

1. Materiality and stakeholder alignment. Conduct double materiality assessments, stakeholder mapping, and executive workshops to confirm priorities.
2. Data foundation. Implement metering, data integration, and governance processes. Document methodologies, controls, and change management procedures.
3. Target setting and planning. Define science-based targets, allocate budgets, and integrate sustainability into strategic plans.
4. Reporting and assurance. Produce CSRD-compliant reports, align with IFRS S1/S2, and secure limited assurance. Automate submissions to regulators and voluntary frameworks.
5. Performance management. Monitor KPIs, run scenario analyses, and recalibrate investments. Benchmark progress using Zeph Tech data and sector indices.
6. Transformation and culture. Embed sustainability into procurement, innovation, and talent management. Maintain continuous improvement cycles and refresh materiality annually.

Use program management offices to coordinate tasks, track dependencies, and report status to the board. Align roadmaps with Zeph Tech’s third-party governance guide to ensure supplier alignment.

Resources and next steps

• Infrastructure insights hub — Weekly updates on regulation, resilience, and sustainability.
• ESG assurance guide — Deep dives on assurance planning and auditor engagement.
• Infrastructure resilience guide — Align climate risk mitigation with physical resilience investments.
• Governance risk oversight guide — Integrate sustainability with enterprise risk management.
• Zeph Tech briefings — Daily intelligence on policy changes, funding programmes, and technology trends.

Use quarterly cross-functional drills to validate data pipelines, rehearse disclosure sign-offs, and capture lessons that feed into policy updates before the next reporting cycle.

Schedule biannual sustainability reporting retrospectives to review assurance findings, stakeholder feedback, and regulatory developments, ensuring disclosures remain accurate, decision-useful, and credible.