🧾 Step 1 – Preparation and Value Chain Mapping

A successful CSRD project starts with clear internal organisation.

• Secure management commitment and define reporting objectives.
• Appoint a central reporting manager and cross‑functional project team.
• Establish a project plan, milestones, resources and budget.

Value chain analysis is a core CSRD concept. Companies must extend their sustainability statement to material upstream and downstream activities, including:

• Raw material suppliers, contract manufacturers and logistics partners.
• Customers, product use, and end‑of‑life stages.
• Associates and joint ventures, where relevant.

Where complete data are not yet available, the ESRS allow the temporary use of sector averages, estimates and other indirect data, provided the company explains the approach and plans to improve data coverage.

⚙️ Step 2 – Applicability and Project Management

Companies should analyse which ESRS topics are potentially relevant by using the official list of sustainability matters in ESRS 1.

• Identify which topics could apply to the business model and value chain.
• Exclude topics that clearly have no connection to the company or its influenceable value chain.
• Formalise project governance, responsibilities and escalation paths.

This early scoping avoids unnecessary effort and prepares the ground for materiality assessment.

📊 Step 3 – Initial Data Collection and Evaluation

Before running a full double materiality assessment, companies need a factual baseline.

• Map existing sustainability data, IT systems and reporting tools.
• Define responsibilities for data collection using a RACI‑type allocation.
• Benchmark peers and sector practices to understand typical impacts and risks.
• Analyse customer and stakeholder expectations through surveys or dialogue.
• Conduct a SWOT assessment on sustainability capabilities and gaps.

👥 Step 4 – Stakeholder Analysis

Stakeholders are central to ESRS and double materiality.

Affected stakeholders may include:

• Own workforce and workers in the value chain.
• Local communities, consumers, and users.
• Suppliers and business partners.
• Nature and ecosystems, often treated as a “silent” stakeholder.

Users of sustainability statements include investors, lenders, insurers, business partners, civil‑society organisations and authorities.

Systematic stakeholder engagement helps to:

• Identify and assess negative impacts.
• Understand expectations and concerns.
• Inform due diligence processes and governance disclosures.

🛡️ Step 5 – Double Materiality Assessment

The heart of the CSRD reporting process is the double materiality assessment.

• Impact materiality considers the scale, scope, likelihood and irreversibility of impacts on people and the environment.
• Financial materiality focuses on how sustainability‑related impacts, risks and opportunities may affect cash flows, financial position, access to finance and cost of capital.

Typical steps are:

• Create a long list of sustainability topics based on ESRS, stakeholder input and risk analyses.
• Identify specific impacts, risks and opportunities for each topic.
• Score them against impact and financial criteria.
• Decide which topics are material and document the rationale.

The ESRS also provide transitional provisions, for example limited value chain data requirements in the first three years and phased‑in disclosures, particularly for companies with fewer than 750 employees.

🎯 Step 6 – Strategic Positioning and Ambition Level

Based on material topics, management should define the organisation’s ambition level:

• Profiling – strong sustainability leadership and proactive communication.
• Best practice – setting or co‑shaping market standards in selected areas.
• Risk minimisation – focusing on legal and market risk reduction.
• Passive behaviour – no longer acceptable for material topics.

For each material topic, companies then build a sustainability programme aligned with ESRS minimum disclosure requirements on:

• Policies, actions and resources, metrics and targets.
• Clear responsibilities, timelines and resource plans.
• Quantitative targets with baselines, performance indicators and monitoring.

🏛️ Step 7 – Governance, Controls and Existing Systems

Many CSRD requirements can be met by leveraging existing management systems and internal rules.

Key governance‑related disclosures include:

• Composition, expertise and responsibilities of management and supervisory bodies for sustainability.
• Integration of sustainability performance into remuneration.
• Features of risk management and internal control around sustainability reporting.
• How strategy, business model and key performance indicators reflect sustainability aspects.
• Processes for identifying impacts, risks and opportunities and assessing materiality.

Relevant management system standards, such as environmental, energy, health and safety, social responsibility or anti‑corruption standards, can provide structures and data that support ESRS compliance.

📜 Step 8 – Determining Information and Data Points

Once material topics and programmes are defined, companies must identify the concrete ESRS data points they need to disclose.

The implementation guidance issued by the European advisory body provides a comprehensive list of:

• Mandatory minimum disclosure requirements for each ESRS.
• Voluntary data points.
• Tabular breakdowns where information must be disaggregated, for example by country.

This list should be used after materiality assessment to build a detailed reporting checklist and data model.

🧾 Step 9 – Creating the Sustainability Statement

The sustainability statement forms a dedicated part of the management report and must follow specific presentation rules.

Key elements include:

• Time horizons and comparability – consistent reporting period with financial statements, clear short‑, medium‑ and long‑term horizons, and comparable base‑year information.
• Use of estimates and uncertainties – disclosure of key assumptions, alignment with financial data, and explanation of significant measurement uncertainties.
• Post‑reporting events, prior‑period errors and consolidated reporting – rules for updating disclosures, restating figures and covering subsidiaries.
• Classified, sensitive and proprietary information – limited options to omit specific items while preserving overall relevance.
• Qualitative characteristics – information must be relevant, faithfully represented, comparable, verifiable and understandable.
• Structure – four main sections: general, environmental, social and governance information, with sector‑specific and entity‑specific disclosures integrated.
• Connectivity – clear links between sustainability information, other parts of the management report and the financial statements, including cross‑references and reconciliations.

✅ Step 10 – Audit, Digital Tagging and Publication

CSRD sustainability information is subject to external assurance.

• Initially, statutory auditors will provide limited assurance over compliance with CSRD and ESRS, the identification of reportable information, EU Taxonomy disclosures and electronic reporting rules.
• From around 2028, assurance is expected to move towards reasonable assurance, requiring more robust systems, controls and documentation.

Publication requirements include:

• Inclusion of the sustainability statement in the management report.
• Filing within the legal deadline (commonly four months after year‑end for large companies).
• Use of the European Single Electronic Format (ESEF) and digital tagging of defined data points using XBRL taxonomies developed at European level.

🤝 Supporting a Robust CSRD Reporting Process

Implementing the CSRD reporting process requires coordinated action across governance, risk management, finance, sustainability and IT.

Specialised compliance partners such as ComplyMarket can support companies by:

• Structuring CSRD projects and value chain mapping.
• Designing and documenting double materiality assessments.
• Aligning policies, actions, metrics and targets with ESRS.
• Preparing for assurance, digital tagging and timely publication.

A disciplined ten‑step approach helps organisations turn CSRD obligations into a transparent, reliable sustainability reporting framework that meets regulatory expectations and stakeholder needs.