How to tackle writing a CSRD report
It’s safe to say the past year has been an interesting time in sustainability reporting. First wave companies scrambled to get their first Corporate Sustainability Reporting Directive (CSRD) reports written, while companies expecting to comply in 2026 began their double materiality assessments (DMA) and tried to plug gaps in their policies and data.
And then, just as the first shiny CSRD reports began to be published, the EU pulled the rug out with the omnibus simplification package. Though it is awaiting final legal approval, the proposals make significant amendments to the CSRD, EU Taxonomy and Corporate Sustainability Due Diligence Directive (CSDDD) and dramatically reduce the number of companies that will need to comply.
The scale of the changes has seen the package labelled as deregulation and a serious dilution of the EU’s green agenda by critical sustainability leaders.
Whether you agree that the move simplifies sustainability reporting rules or goes too far, the timing has been far from ideal. Many companies have been left pondering if or when they will be expected to comply and ruin the time and effort already invested. That said, there are still up to 10,000 companies that will need to play ball with the CSRD at some stage, and first wave companies will soon be beginning their next reports. So CSRD is not going away.
The number of compliant reports in the market continues to grow and many major global players are still in scope. With that in mind, we have reflected on the lessons we learned from writing our first sustainability statement in line with the ESRS (European Sustainability Reporting Standards) to help you have a smoother process and a better end result.
Don’t lose your story and your voice
Compliance alone should never be the sole goal of any reporting project. In the case of CSRD, meeting the hundreds of material data requirements of the ESRS will likely result in a clunky draft. Potentially comprised of many independent statements that do not necessarily connect or flow, it will look nothing like your previous sustainability reports.
Adding introductions, explanations and context is vital for creating a functional and engaging story that works for your audience. Leveraging key narrative and messaging you have used before to supplement the new data requirements can help readers understand that your story is the same and ensure your voice is still coming through loud and clear.
Information gathering requires time and planning
Contributors from all corners of your business will need to provide information for your sustainability statement, but getting to grips with the requirements of the ESRS takes time.
It is vital to properly brief your contributors to ensure they understand the data-driven direction reporting has taken and the data points they are responsible for. Briefing sessions and guides should be prepared, and sharing the wording of ESRS disclosure requirements can help them to consider the exact question they are answering.
The questions can be complex, so we think allowing contributors to populate their answers offline works better than a face-to-face interview, as it provides time and space to do any necessary fact finding, collaborating and confirming their position.
This thorough approach should ensure contributors are able to cut through the complexity, feel engaged and empowered about contributing to the project, and provide a solid foundation to build your report on.
Comply but remember reporting principles
One of the motivators for the omnibus changes was the backlash to the complexity and scale of complying with the CSRD. For first wave reporters, the task was made harder by a lack of guidance on structuring your sustainability statement and no compliant examples to learn from.
Faced with this challenge, we leaned into our vast reporting experience and focused on go-to principles of being concise and ensuring a logical narrative flow.
The ESRS takes a belt and braces to disclosure, with repetition rife across the standards. Through clear references and navigation – including pointing the reader outside the sustainability statement for information on strategy, business model and governance that’s well established elsewhere in the annual report – we made sure that information was duplicated as little as possible.
In terms of flow, following the order of the ESRS disclosure requirements may appear to be the obvious structure to use, but there were certain aspects we didn’t agree with. For example, the ESRS puts actions before targets, however, we feel targets provide vital context and reasoning that helps the audience to understand why certain actions have been taken. As long as all the information is there, we felt that the story should unfold as it always has.
If you have a CSRD report to create, or simply want to embrace some of the positives of this new way of sustainability reporting, we’re here to help. Whether that’s guiding your contributors and writing the first draft, or editing a draft at any stage, we can help you to balance compliance with storytelling and ensure maximum impact for your audience.
