How Companies Can Get Ready for CSRD Reporting

Last updated: May 28, 2026. Preparing for CSRD reporting in 2026 starts with a different question than it did a year ago. Before building a full report, companies should confirm whether they are still in scope, delayed by stop-the-clock, affected by Omnibus I scope changes, indirectly exposed through customers or lenders, or outside mandatory CSRD but still likely to receive sustainability data requests.

Short answer: do not start with report writing. Start with a scope and timeline check. The EU stop-the-clock directive delayed wave two and wave three reporting by two years. The 2026 Omnibus I directive narrowed mandatory CSRD scope to companies with more than 1,000 employees and above EUR450 million net annual turnover, with special rules for third-country groups and transition relief for some wave one companies falling out of scope. Companies that remain in scope should prepare for ESRS-based reporting, double materiality, EU Taxonomy where relevant, greenhouse gas calculations, evidence files, and limited assurance. Companies outside scope should still prepare a smaller data pack if customers, banks, investors, or procurement teams ask for sustainability information.

Step 1: Check whether CSRD still applies

The first readiness task is not a gap analysis. It is an applicability check. Older CSRD guides often describe the original rollout, where many large EU companies, listed SMEs, and certain non-EU groups were expected to enter reporting in waves. That timetable changed.

Companies should now answer:

Which legal entity or group is being assessed?
Which Member State law applies?
Was the company originally wave one, wave two, wave three, or a third-country case?
Does the company exceed the amended threshold of more than 1,000 employees and above EUR450 million net annual turnover?
Is there a relevant EU listing, subsidiary, branch, parent-company rule, insurance activity, banking activity, or national-law requirement?
Did stop-the-clock delay the first reporting year?
Does the company fall out of scope but still need transition relief, voluntary reporting, lender disclosure, supplier disclosure, or customer-request support?

This check matters because the right preparation path differs. A wave one company that remains in scope needs report and assurance readiness. A company that is delayed may have more time but should still build data foundations. A company that falls out of mandatory scope may need a proportionate sustainability data pack rather than a full ESRS report.

Step 2: Decide the right level of preparation

CSRD readiness is not all-or-nothing. The practical level of work should match the company's actual exposure.

Full CSRD route: for companies that remain in mandatory scope and need ESRS reporting, a sustainability statement, evidence, and assurance readiness.
Delayed CSRD route: for companies that are likely to report later, a staged readiness programme that builds data and governance without overbuilding too early.
Value-chain route: for suppliers that are not in scope themselves but receive sustainability data requests from customers that are in scope or under pressure from lenders or investors.
Voluntary or lender route: for companies using sustainability reporting to answer financing, procurement, investor, or tender requirements.
Out-of-scope monitoring route: for companies that appear outside CSRD now but should track Member State implementation, EU amendments, and customer-request trends.

This avoids two bad outcomes: spending heavily on a full report that is not required, or pausing all sustainability data work and then being caught unprepared by a customer, bank, investor, tender, or future reporting deadline.

Step 3: Build the reporting boundary

Before collecting data, define the reporting boundary. A reporting boundary explains which legal entities, operations, countries, sites, business units, and value-chain activities are included. Without it, data collection becomes messy and later assurance becomes harder.

The boundary should cover:

legal entities and ownership structure;
consolidation approach and relationship to financial reporting;
sites, operations, and countries included;
leased assets, joint ventures, and outsourced activities;
where value-chain data is expected; and
which data owners are responsible for each topic.

Finance should be involved early. CSRD reporting is not a detached ESG brochure. It connects sustainability information to business model, strategy, risk, financial effects, governance, controls, and assurance.

Step 4: Run a double materiality assessment

Double materiality is central to ESRS reporting. It asks two linked questions: where does the company have actual or potential impacts on people and the environment, and where do sustainability matters create financial risks or opportunities for the company?

A useful double materiality process usually includes:

a long list of potentially relevant sustainability matters;
sector and business-model screening;
internal stakeholder input from finance, risk, legal, operations, HR, procurement, and sustainability teams;
external stakeholder input where relevant;
impact assessment across severity, scale, scope, likelihood, and time horizon;
financial materiality assessment across risks, opportunities, dependencies, and expected financial effects;
documentation of scoring, thresholds, judgments, and approvals; and
a final list of material topics mapped to ESRS disclosure requirements.

The goal is not to make every ESG topic material. The goal is to document a defensible process that explains which topics matter, why they matter, and what the company will report.

Step 5: Map ESRS disclosure gaps

Once material topics are known, compare current reporting against ESRS requirements. The first set of ESRS includes cross-cutting standards and topical standards covering environmental, social, and governance matters. In 2025, EFRAG submitted draft simplified ESRS technical advice to the European Commission, but companies should track adoption before treating draft changes as final law.

A practical ESRS gap assessment should identify:

which disclosures are likely required for material topics;
which current policies, actions, metrics, and targets already exist;
which disclosures need new data or new governance processes;
where finance, risk, HR, procurement, legal, operations, or IT input is needed;
where Scope 1, Scope 2, and Scope 3 emissions data is missing;
where EU Taxonomy reporting may apply; and
where evidence is not strong enough for limited assurance.

This step turns CSRD from an abstract regulation into a concrete workplan.

Step 6: Build a data request and evidence pack

Data is usually the bottleneck. Companies often have sustainability information scattered across invoices, HR systems, facilities records, procurement data, spreadsheets, travel platforms, ERP systems, board papers, policies, and email attachments.

The data request should be clear enough for non-sustainability teams to use. It should specify the metric, owner, reporting period, unit, source document, methodology, assumptions, review process, and deadline.

For CSRD readiness, the evidence pack should include:

source files and calculation workbooks;
methodology notes and emission factors;
data-owner sign-offs;
policy and procedure documents;
board and management review evidence;
materiality assessment documentation;
target calculations and progress evidence;
EU Taxonomy eligibility and alignment evidence where relevant; and
a change log showing updates, restatements, and judgments.

Step 7: Prepare greenhouse gas calculations early

Climate reporting is one of the hardest parts to fix late. Even companies outside full CSRD scope often receive customer or lender requests for emissions data. Companies that remain in scope should expect greenhouse gas information to receive close scrutiny from management, assurance providers, investors, and customers.

A CSRD-ready emissions inventory should cover:

Scope 1 emissions from owned or controlled fuel use, vehicles, generators, refrigerants, and industrial processes;
Scope 2 emissions from purchased electricity, heating, cooling, or steam;
relevant Scope 3 categories where material or requested;
clear organizational and operational boundaries;
activity data by site, business unit, or geography where useful;
emission factors and calculation methodology;
treatment of estimates, exclusions, missing data, and restatements; and
management review and evidence files.

Starting emissions work early also helps companies answer supplier questionnaires, procurement requests, customer GHG requests, CDP questionnaires, lender ESG checks, and annual refreshes.

Step 8: Design governance and controls

CSRD readiness is not just a sustainability-team project. It needs governance and controls similar to financial reporting. Companies should define who owns each topic, who reviews the data, who approves judgments, and how evidence is retained.

At minimum, companies should define:

board or committee oversight;
management accountability;
finance involvement;
data owners and reviewers;
internal control checks;
escalation routes for missing or unreliable data;
document retention and version control; and
assurance-provider interaction points.

Good governance also helps avoid greenwashing risk. A claim should not enter the report unless the company can show who approved it, what evidence supports it, and what boundary or assumption sits behind it.

Step 9: Prepare for limited assurance

CSRD reporting is subject to assurance. The Omnibus I directive changes the future assurance trajectory by postponing the deadline for limited assurance standards and removing the previous requirement to adopt reasonable assurance standards on the earlier timetable. That does not remove the need for discipline.

Limited assurance still requires consistent methodology, evidence, management review, and data controls. Companies should conduct a pre-assurance review before final reporting. This can identify weak data, unclear boundaries, unsupported claims, missing sign-offs, inconsistent units, and methodology gaps before the assurance provider sees the report.

Step 10: Write the report last

The sustainability statement should be the output of the process, not the starting point. Once the scope, boundary, material topics, data, evidence, and controls are in place, the report can explain the company's governance, strategy, risks, impacts, metrics, targets, policies, and actions in a clear structure.

Companies should avoid broad ESG storytelling that is not connected to material topics, data, and evidence. The strongest CSRD-style reports are practical, specific, and traceable. They explain what the company knows, what it is doing, what has changed, and where limitations remain.

What if your company is outside mandatory CSRD scope?

Many companies will now be outside mandatory CSRD reporting. That does not mean they should ignore sustainability data. Large customers, banks, investors, and public-sector buyers may still request information, especially where the company is part of a reporting company's value chain.

For out-of-scope companies, a proportionate readiness pack may be enough:

company profile and reporting boundary;
basic sustainability policies;
Scope 1 and Scope 2 emissions calculations;
selected Scope 3 data if customers ask for it;
workforce and health-and-safety indicators;
supplier and governance policies;
methodology notes and evidence; and
a clear explanation of limitations, estimates, and annual refresh timing.

This route is often more useful for suppliers than preparing a full ESRS report. It gives customers and lenders enough credible information without creating a disproportionate reporting burden.

How Keslio can help

Keslio helps companies turn CSRD uncertainty into a practical readiness plan. We can support:

CSRD scope and timeline checks;
readiness route selection for in-scope, delayed, out-of-scope, and supplier cases;
double materiality planning and documentation;
ESRS gap assessments;
data request templates and evidence trackers;
GHG emissions calculations for Scope 1, Scope 2, and relevant Scope 3 categories;
EU Taxonomy readiness support where relevant;
sustainability reporting and communications support;
supplier and customer-request response support; and
annual refreshes once the reporting process is in place.

Official sources and further reading

Conclusion

Getting ready for CSRD reporting in 2026 means being precise. Some companies still need full ESRS reporting. Some are delayed. Some may fall out of scope. Some are not directly covered but still need sustainability information for customers, banks, investors, or tenders.

The best first move is to confirm the route, then build the data, evidence, governance, and reporting process needed for that route. That keeps the work proportionate while making sure the company is ready when a regulator, assurance provider, lender, or customer asks for credible sustainability information.