The CSRD will reach you through a customer questionnaire

The CSRD, the European directive on sustainability reporting, replaces the NFRD and widens what large companies operating in the Union must disclose. The list of subjects is broad: environmental impact, social responsibility, human rights, anti-corruption measures, and the composition of boards.

Why a company outside its scope is still concerned

Most of a company's environmental footprint sits outside its own walls, in its value chain. A company in scope therefore cannot answer alone: it questions its suppliers, its partners and its subcontractors. That is how the directive reaches businesses that owe it to no one, and why it rarely arrives as a piece of regulation. It usually arrives as a spreadsheet to fill in, with a deadline.

A measurement problem before a disclosure problem

A questionnaire is quick to complete when the data exists and slow when it has to be reconstructed. The difficulty is almost never the formatting: it is finding, across the months just past, consumption figures, volumes or readings that nobody thought to record. Data that was not collected at the time cannot be recovered. It gets estimated, and an estimate holds up poorly under verification.

Five pieces of work, in this order

• Establish what matters, in both directions: what environmental and social issues do to the business, and what the business does to its environment.
• Read the ESRS standards, which set the expected indicators and therefore the shape the questions will take.
• Organise the collection: identify the data to gather across operations and suppliers, then make the readings reliable rather than presentable.
• Bring sustainability factors into the risk management already in place, instead of running a second process alongside it.
• Structure the disclosure on the assumption that independent verification will read it afterwards.

What can be decided now

The first step is inexpensive: open the list of data a customer might ask for, and mark the items that are currently recorded nowhere. The rest, scoping, standards and verification, can be handled in order. What cannot be recovered is the time during which nothing was measured. France's financial markets authority publishes official guidance on the scope and the timetable.