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Navigating ESRS Reporting in 2025: Key Insights from EFRAG's New Portal and Simplification Efforts

· 6 min read
José Heitor Soares
Co-Founder EXO

The EFRAG Portal: A Glimpse into Early ESRS Implementation

The "EFRAG 2025 State of Play" portal stands as a live, interactive platform, meticulously designed to provide crucial insights from EFRAG's market study on the initial adoption of ESRS under the CSRD. Its core functionalities include a "Statistics Dashboard," which allows users to explore overall trends and metrics derived from 656 sustainability statements issued in 2025, and a "Report Repository," offering access to the complete set of analyzed company reports collected between January 1 and April 20, 2025. Complementing these interactive features, an accompanying "State of Play 2025" report is also available in PDF format, summarizing the statistics and offering key observations.

This portal serves as a critical tool for a diverse range of stakeholders. For preparers, it offers an opportunity to benchmark their own reporting practices against peers, identifying areas where improvements can be made. For investors, civil society organizations, and consumers, the portal significantly enhances transparency and comparability, enabling a more informed evaluation of companies' sustainability performance and associated risks. This directly addresses the historical "accountability gap" where reported sustainability information was often insufficient, difficult to compare, and lacked reliability.

Key Findings from the "State of Play 2025" Report

EFRAG's comprehensive analysis of the first 656 sustainability statements offers crucial insights into the initial phase of ESRS implementation:

Materiality Coverage: A significant finding from the report is the varied application of the double materiality principle. Only 10% of the analyzed companies identified all 10 topical ESRS standards as material. The most frequently disclosed topical standards were Climate Change (E1), Own Workforce (S1), and Business Conduct (G1). The data further reveals that more than half (52%) of preparers disclosed between 4 and 6 material topical standards, while approximately 25% reported 4 or fewer.

Stakeholder Engagement Gaps: The study uncovered a notable disparity in stakeholder engagement during materiality assessments. A vast majority, 97%, of companies involved internal stakeholders, primarily employees. However, engagement with broader societal stakeholders, such as authorities, Non-Governmental Organizations (NGOs), Industry Unions and Academia, remained considerably less common. This contrast between high internal engagement and low broader societal stakeholder involvement in materiality assessments highlights a significant area for improvement in operationalizing the "impact materiality" aspect of double materiality.

Climate Transition Plans: The report indicates that 55% of companies disclosed a climate transition plan, indicating that initial reporting on this topic is ongoing. However, a key observation is the variation in approaches and formats for these plans, highlighting different levels of maturity. Encouragingly, approximately 70% of preparers reported having near-term (2030 or earlier) Scope 1 & 2 targets compatible with the 1.5°C global warming limit. However, the absence of similar data for Scope 3 emissions (often the largest portion of emissions for many companies) suggests a potential reporting challenge or a less mature area of focus. This indicates that while companies are setting targets, the specific methodologies for achieving and reporting on these targets are still developing, posing challenges for stakeholders seeking actionable insights into climate resilience.

Reporting Depth and Length: The sustainability statements analyzed varied widely in length, ranging from 70 to over 200 pages on average. Financial institutions, in particular, tended to produce longer reports.

Underreported Topics: The study identified specific areas with limited disclosures. Topics such as biodiversity (E4) and internal carbon pricing showed restricted reporting. Furthermore, human rights incidents were rarely reported, even when other social data was present. The consistent underreporting of these topics points to inherent complexities in data collection, measurement, and materiality assessment within these areas. Unlike climate change, which has more established methodologies and frameworks, topics like biodiversity and human rights often involve more qualitative data, require specialized expertise, or necessitate deeper engagement across extended value chains.

Recommendations

Given the dynamic and evolving landscape of ESRS, companies subject to these regulations should adopt a proactive and strategic approach to their sustainability reporting.

Revisit and Refine Materiality Assessments: Companies should embrace the simplified, top-down Double Materiality Assessment (DMA) approach, focusing on identifying truly material impacts, risks, and opportunities relevant to their specific business model, rather than attempting to report on every single data point. A critical area for improvement, as identified in the "State of Play" report, is strengthening engagement with broader societal stakeholders beyond internal teams to ensure a comprehensive understanding of impact materiality. This will lead to more relevant and credible disclosures.

Streamline Report Structure and Content: Preparers should anticipate and prepare to incorporate an executive summary at the beginning of their sustainability statement to highlight key strategy, metrics, and future outlook upfront. To enhance readability and conciseness, consider relocating detailed or highly technical data, such as EU Taxonomy disclosures, to dedicated appendices. The focus should be on presenting core, decision-useful information in the main body of the report, avoiding over-reporting on non-material or voluntary disclosures unless there is a clear strategic benefit.

Optimize Data Collection and Management: Companies should leverage the new flexibility regarding value chain data. Where direct data from smaller suppliers is not feasible or disproportionately costly, preparers should be ready to use robust estimates or industry data, ensuring transparency in their methodology. Investing in comprehensive data management systems is crucial for accurately tracking ESG performance across complex operations and supply chains. Furthermore, it is advisable to prioritize improving data collection and reporting for currently underreported topics like biodiversity and human rights incidents, as these areas are likely to remain subjects of significant regulatory and stakeholder scrutiny.

Stay Engaged with Regulatory Developments: Active participation in public consultations, such as EFRAG's upcoming consultation (expected from late July to early September 2025), offers a valuable opportunity to influence the final standards and voice practical concerns. Continuous monitoring of legislative updates is also essential, particularly concerning the finalization of the simplified ESRS by October 2025 and their anticipated adoption by mid-2026.

Embrace Interoperability: For multinational companies, aligning internal data collection and reporting processes with both ESRS and ISSB standards is a strategic imperative. This approach can significantly reduce duplication of effort and enhance the global comparability of sustainability disclosures, providing a more consistent narrative to a global audience.


The launch of EFRAG's ESRS Statistics and Report Portal provides great insights into the early implementation of ESRS, revealing both significant progress and areas requiring further refinement.

As the ESRS framework evolves towards a more principles-based and materiality-driven approach, companies are presented with a unique opportunity to move beyond mere compliance. By strategically adapting their reporting processes, focusing on decision-useful information, and embracing the spirit of transparency, businesses can not only meet their regulatory obligations but also unlock new avenues for value creation, enhance stakeholder trust, and contribute meaningfully to a more sustainable economy. The future of sustainability disclosure is one of continuous improvement, informed by real-world data and driven by a shared commitment to accountability and positive impact.

The New Recommendation for SMEs Sustainability Reporting

· 5 min read
José Heitor Soares
Co-Founder EXO

SME Sustainability Reporting

On July 30, 2025, the European Commission formally adopted a recommendation introducing a Voluntary Sustainability Reporting Standard for non-listed Micro-, Small-, and Medium-sized Enterprises (VSME). Developed by EFRAG, this initiative provides a streamlined, standardized, and accessible framework to help SMEs engage in sustainability reporting.

Non-listed SMEs are not directly required to report under the Corporate Sustainability Reporting Directive (CSRD), yet they face growing pressure to provide ESG data to large business partners and financial institutions. These stakeholders, subject to mandatory disclosure requirements, can cascade data demands down their value chains. As a result, SMEs will be burdened with fragmented, repetitive ESG questionnaires, leading to inefficiencies, duplicated efforts, and rising operational costs.

This voluntary standard aims to replace the multitude of uncoordinated ESG data requests, thereby increasing efficiency and lowering operational costs. Furthermore, the Recommendation is expected to enhance SMEs' access to sustainable finance by providing credible and comparable sustainability data. By encouraging large companies to base their data requests on the VSME, the Commission positions it as a de facto market standard, promoting greater consistency across supply chains.

The VSME reflects a forward-thinking regulatory approach, with the goal of enabling broad participation in sustainability efforts without stifling growth or competitiveness.

The VSME characteristics

The VSME is specifically designed for companies that are not publicly traded and are not subject to the mandatory Sustainability Reporting. Its primary target audience comprises undertakings with fewer than 250 employees (micro, small, and medium-sized enterprises), while it can apply to bigger companies that are willing to start their reporting journey.

Key features:

  • It is voluntary
  • Intended for companies with fewer than 250 employees
  • Aligned with the European Sustainability Reporting Standards (ESRS)
  • Covers complete Environmental, Social & Governance (ESG) topics
  • Tailored to the size, capacity, and needs of SMEs

A Modular and Flexible Approach

The VSME standard is structured around a two-module approach, a design choice to ensure proportionate and adaptable reporting for the diverse sizes and capabilities of SMEs. This modularity allows businesses to choose a level of detail that best matches their needs.

The Basic Module

This module is intended as the entry-level for all SMEs embarking on their sustainability reporting journey. It is specifically highlighted as the target module for micro undertakings (defined as SMEs with fewer than 10 employees), providing a manageable starting point. It comprises 11 core disclosures that focus on key sustainability indicators most frequently requested by value chain partners. These are the fundamental data points that provide essential transparency.
Key disclosures within this module include Greenhouse Gas (GHG) emissions (Scope 1 and 2), other environmental metrics, own-workforce data, and anti-corruption measures. It provides general information and basic metrics across environmental, social, and governance areas.

The Comprehensive Module

This module builds upon the Basic Module, offering a more in-depth reporting framework for SMEs that need or wish to provide more detailed sustainability information, it includes 9 additional disclosures. These supplementary disclosures are often sought by banks and investors, as well as value chain partners who require a more understanding of an SME's sustainability performance. Examples of disclosures in this module cover a brief description of ESG practices or future initiatives (disclosure C2), GHG reduction targets and climate transition plans (disclosure C3), confirmed value chain incidents (disclosure C7), and information related to exclusion from EU reference benchmarks (disclosure C8).

A cornerstone of the VSME's design, aimed at reducing complexity, is that it does NOT require a mandatory materiality assessment. This stands in stark contrast to more complex reporting frameworks, which mandate a rigorous double materiality assessment process. Instead, the VSME promotes flexibility and usability through an "if applicable" conditionality. This means that undertakings are only required to apply and report on sustainability topics and disclosures that are genuinely relevant to their specific operations and business activities. If a particular disclosure does not apply to a company, there is no obligation to report on it, significantly simplifying the process. While a formal assessment is not mandated, even a simplified analysis of materiality can be beneficial. This helps companies identify which data points are most pertinent to their business, ensuring the reported information is truly meaningful and impactful.

Digital Tools and Ecosystem Support

To support the adoption of the Voluntary Sustainability Reporting Standard for SMEs (VSME), EFRAG has introduced a suite of digital tools, including an Excel template, XBRL taxonomy, and an XBRL converter for generating machine-readable disclosures. These resources, available on EFRAG's website, will soon support multiple languages and include additional mappings to tools like GHG calculators. EFRAG is also developing practical guides to help SMEs draft their disclosures on key topics such as sustainable transition practices (C2), climate targets and transition planning (C3), and severe human rights incidents within the value chain (C7).

EXO.G platform builds on this foundation by providing SMEs with an intuitive, AI-powered platform that simplifies ESG data collection and report generation, fully aligned with VSME framework. With features such as guided reporting, modular templates, and collaborative tools for engaging suppliers, EXO.G ensures that even non-experts can confidently create compliant, transparent, and impactful ESG reports.
EXO.G transforms regulatory requirements into strategic opportunities by empowering companies to move beyond compliance and toward performance-driven sustainability. Instead of treating ESG as a reporting obligation, EXO.G helps businesses unlock value through data-driven, actionable insights and strategic roadmaps for improvement.

The platform simplifies frameworks like the VSME standard into guided workflows, enabling institutions to collect and structure data efficiently, even without in-house sustainability teams. Using AI and robust analytics, it transforms that data into clear diagnostics, benchmarking intelligence, and customized action plans to reduce risks, improve efficiency, and elevate ESG performance.

As EFRAG expands its resources, EXO.G integrates them into a seamless user experience, helping SMEs transform regulatory requirements into strategic opportunities.

The impact of GRI's New Climate and Energy Standards

· 4 min read
José Heitor Soares
Co-Founder EXO

The impact of GRI's New Climate and Energy Standards

The Global Reporting Initiative (GRI) has increased the requirements for corporate sustainability disclosure with its new Climate Change (GRI 102) and Energy (GRI 103) Standards. Driven by urgent stakeholder demands and global climate goals, these updates are a call to action for businesses worldwide.


What's New and Why It Matters

These updated standards replace the older GRI 302, 305 (Disclosures 305-1 to 305-5) and GRI 201 (Disclosure 201-2), bringing enhanced rigor and scope to climate and energy reporting. Effective January 1, 2027, they shift the focus from mere metrics to strategic, impactful disclosure.

GRI 102: Climate Change

GRI 102: Climate Change, which integrates and revises content from most of GRI 305: Emissions and the Disclosure 201-2: Financial implications and other risks and opportunities due to climate change, focuses on how organizations influence the climate and how they manage these influences. This standard introduces several critical features and objectives, such as reporting on how climate mitigation and adaptation plans impact workers, communities, and vulnerable groups. This adds a crucial social equity dimension to climate action, ensuring businesses address human impacts alongside environmental ones.

GRI 103: Energy

GRI 103: Energy, which completely replaces GRI 302: Energy, enables an organization to publicly disclose its most significant energy-related impacts and how it manages them. This standard reflects an enhanced comprehension of how energy use influences climate change and aligns with pressing global commitments to mitigate climate change, consistent with IPCC recommendations and the Paris Agreement goals. This will enable organizations to disclose on energy consumption, reduction, efficiency, and renewable energy sources with a focus on impacts associated with energy consumption and transition to renewables.

Interoperability

Both standards are designed to work seamlessly with other major frameworks like the ISSB's IFRS S2, the EU's ESRS (under CSRD), and the Science Based Targets initiative (SBTi). This helps reduce reporting duplication for multinational companies.


Practical Implications: Challenges & Opportunities

Implementing these new standards includes challenges and advantages.

Challenges:

  • Increased Data Demands: Companies will need to collect more data on energy, value chain impacts, and social dimensions.
  • Robust Data Systems: Upgrading existing systems or investing in new ESG software is crucial for managing this data accurately and efficiently.
  • Cross-Functional Collaboration: Success hinges on coordination between different teams.
  • Supply Chain Pressure: Large companies will need to engage with suppliers, including SMEs, to gather necessary value chain data.

Opportunities:

  • Enhanced Credibility & Transparency: Detailed reporting builds trust with investors, customers, and regulators.
  • Future-Proofing Reporting: Aligning with these leading standards ensures your reporting meets evolving global expectations.
  • Improved Decision-Making: Deeper insights into energy use and climate impacts enable better strategic planning and risk management.
  • Leadership in Climate Action: Proactive adoption positions companies as leaders in sustainable business practices.

Your Next Steps

To prepare effectively, businesses should:

  1. Assess Readiness: Evaluate current reporting processes and data systems against the new GRI 102 and 103 requirements.
  2. Invest in Systems: Consider ESG software to streamline data collection, ensure accuracy, and support alignment with multiple frameworks.
  3. Refine Strategy: Integrate transition principles into climate mitigation and adaptation plans, aligning targets with global scientific consensus.
  4. Stay Informed: Keep an eye on updates from GRI and other standard-setters to leverage interoperability and maintain compliance.

Conclusion

The new GRI Climate Change and Energy Standards can be powerful tools for driving meaningful climate action and corporate accountability. By adopting these standards, organizations can meet stakeholder demands and assess their impacts and costs, which must be addressed efficiently to ensure greater savings. It's a strategic move that enhances credibility, fosters trust, and accelerates growth.

5 Business Insights You Can Unlock with Your ESG Report

· 5 min read
Tito Sala
Co-Founder EXO

Feeling the regulatory whiplash from Brussels? You're not alone. The European ESG landscape is in a state of intense flux. A political drive to ease administrative burdens is clashing head-on with the EU Green Deal's core mission, leaving C-suite leaders caught in a storm of uncertainty.

Many are tempted to hit pause on their ESG strategy, waiting for the dust to settle. This is a strategic mistake.

While the rules of the game may be shifting, the fundamental drivers of sustainability—investor demands, market risks, and consumer expectations—are only accelerating. This article cuts through the noise to reveal how to turn your ESG report from a compliance burden into a strategic intelligence tool that unlocks five crucial business insights.

The Great Unraveling? Understanding the Proposed Changes

The core of the current "whiplash" comes from a significant political push to reduce the regulatory scope of both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

  • June 2025: The European Council endorses a negotiating mandate proposing drastic scope reductions for both CSRD and CSDDD.
  • July 2026: Original transposition deadline for the CSDDD, now likely to be pushed back significantly.
  • July 2028: The proposed new transposition deadline for the CSDDD under the Council's mandate, prolonging uncertainty.
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The Proactive Advantage vs. The Compliance Trap


Companies that pause their ESG efforts risk being caught flat-footed by regulatory snap-backs or evolving investor demands. In contrast, organizations that use this period to build a solid ESG data architecture will be more resilient, more attractive to capital, and ultimately more competitive.

Beyond Compliance: 5 Strategic Insights from Your ESG Report

Viewing ESG reporting as a mere burden is the fastest way to miss its true value. Here's how to reframe the process from a cost center to a value driver.

Insight 1: Identify Hidden Operational Inefficiencies

Your ESG data on energy, water, and waste is a direct proxy for operational waste and squandered revenue. Analyzing this data reveals hidden cost-saving opportunities.

  • Energy & Water Use: Pinpoint inefficient facilities and processes.
  • Waste Streams: Quantify the cost of wasted raw materials.

Insight 2: De-risk Your Entire Supply Chain

Real-world risk—from climate events to labor crises—hides deep in your value chain. Mapping these risks before they escalate into crises is fundamental.

  • Climate Risk: Map supplier locations against data on water stress and floods.
  • Social Risk: Screen for dependencies in regions with high risks of forced labor or instability.

Insight 3: Win the War for Talent

In a competitive labor market, culture is an advantage. The social data in your ESG report (DEI metrics, employee turnover, pay equity) is the key to becoming an employer of choice.

  • Attract Talent: Use transparent data to build trust.
  • Retain Talent: Analyze turnover and well-being data to diagnose cultural issues.

Insight 4: Drive Product and Service Innovation

Your ESG report is an R&D engine waiting to be ignited. Analyzing data on product life-cycles and customer expectations can spark the next generation of sustainable offerings.

  • Circular Economy: Use data on material flows (ESRS E5) to design for remanufacturing and recycling, opening new revenue streams.
  • Sustainable Innovation: Identify opportunities to substitute conventional materials with lower-impact alternatives, creating premium products that command higher margins.
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The Circular Economy Opportunity: Market analyses project that the European automotive circular economy market alone will grow to over $100 billion by 2034. Companies like Renault with its "RE:Factory" are already capitalizing on this trend.

Insight 5: Strengthen Brand and Reputation

In an age of skepticism, trust is your most valuable currency. A transparent, data-backed ESG report is your strongest defense against "greenwashing" accusations and your most powerful tool for building an unbreakable brand.

  • Win Over Investors: Investors demand credible data. A robust, auditable report is now a prerequisite for effective capital markets communication.
  • Build Trust: Reporting honestly on progress—and challenges—builds a level of authenticity that traditional marketing cannot achieve, solidifying trust with customers, regulators, and NGOs.

Your Strategic Action Plan

The intelligent response to regulatory uncertainty is not to stop, but to build the right foundations.

Your 3-Step ESG Action Plan

  • Conduct a "No Regrets" Materiality Assessment: Identify the ESG risks and opportunities that impact your bottom line, regardless of regulation.
  • Build a Unified Data Foundation: Consolidate your ESG data and integrate it with financial and operational systems to create a Single Point of Truth (SPOT).
  • Reframe Your Reporting: Shift your mindset from compliance to strategy. Use your data to tell a compelling story of value creation.

From Data Points to Decisions: The Final Word

The current regulatory chaos in Europe is a test of leadership. Companies that see only a compliance burden will fall behind. But those that recognize this as a strategic moment to build a truly data-driven, resilient, and efficient enterprise will emerge as the leaders of tomorrow.

Reporting is the output. Insight is the outcome.

Don't let your ESG data gather dust in a report. Our platform is designed specifically to transform your raw ESG data from a complex compliance headache into the strategic intelligence that fuels your company's future.

Ready to move beyond compliance? See how our platform turns ESG data into your competitive advantage.

Why Wait for Regulation? The Competitive Imperative for ESG Action is Now

· 7 min read
Tito Sala
Co-Founder EXO

The recent news from Brussels might feel like a reprieve. The EU's "Omnibus" reforms have officially delayed timelines for the Corporate Sustainability Reporting Directive (CSRD) and narrowed the scope of the Corporate Sustainability Due Diligence Directive (CSDDD). For many companies, this seems like a green light to press pause on their ESG strategy and investments.

This would be a strategic mistake.

While the number of companies with a direct legal obligation to report has shrunk—by an estimated 80% in the case of CSRD[1]—the indirect market demand for high-quality, verifiable sustainability data has never been stronger. The legislative shifts haven't eliminated the need for ESG reporting; they have simply changed the mechanism of demand from a regulatory push to a powerful market pull.

The New Reality: Your Customer is the Regulator

The most significant consequence of the EU's legislative recalibration is the creation of a "data chasm." The largest global corporations—your potential customers—remain squarely in the scope of both CSRD and CSDDD. They are legally required to report on the risks and impacts across their entire value chain.

This means that even if your company is no longer directly regulated, if you are a supplier to a large, in-scope enterprise, you will be required to provide them with detailed data on your environmental, social, and governance performance.

Think of it this way: your customer's compliance has become your business imperative. They will need to know your carbon footprint, your labor practices, and your water usage to complete their own mandatory reports.[2] Companies that can provide this information efficiently and accurately will become preferred suppliers. Those who cannot will risk being designed out of the value chain. In this new landscape, a robust ESG data strategy is no longer a "nice-to-have"; it is a prerequisite for market access and a powerful competitive differentiator.

Beyond the Value Chain: The Unwavering Demands of Capital

The regulatory floor set by Brussels is not the ceiling. The forces driving corporate sustainability extend far beyond the EU's directives.

  • Investors and Lenders: Financial institutions are increasingly sophisticated in their use of ESG data to assess risk and identify opportunities. A brand new June 2025 survey found that 88% of corporations now view sustainability as a key opportunity for creating long-term value.[3] Access to capital and favorable lending terms are progressively being linked to a company's ability to demonstrate how it is managing climate risk and other sustainability challenges.

  • Insurers: The insurance industry is on the front lines of climate change. Insurers are using advanced ESG analytics to price risk, and companies with poor environmental management or a lack of a credible transition plan may face higher premiums or even find it difficult to secure coverage.

  • Talent: The best and brightest employees want to work for companies that align with their values. A clear and authentic commitment to sustainability is a critical tool in the global war for talent. According to Deloitte, 59% of C-suite leaders report that "employee activism" has directly caused them to increase their company's sustainability efforts over the past year.[4]

These market forces are not subject to legislative delays. They are active now and are creating real financial consequences for businesses.

The Definitive Implementation Timeline

CSRD: Wave 1 Reports

Large PIEs (>500 employees) previously under NFRD publish first reports based on FY2024.

2025

CSDDD: Transposition Deadline

Member states must have the CSDDD transposed into national law by July 26.

2027

CSRD Wave 2 & CSDDD Phase 1

Other "large" companies begin CSRD reporting. CSDDD rules apply to largest firms (>5,000 employees & >€1.5B turnover).

2028

CSRD Wave 3 & CSDDD Phase 2

Listed SMEs begin CSRD reporting. CSDDD expands to firms >3,000 employees & >€900M turnover.

2029

CSDDD: Phase 3 Compliance

CSDDD fully phased-in, applying to firms >1,000 employees & >€450M turnover. Note: Omnibus may eliminate Phases 2 & 3.

2030

The Strategic Opportunity in the Delay

The "Stop the Clock" directive is not a pause button; it is a head start. The one-to-two-year delay provides a crucial window for companies to move beyond a reactive, compliance-focused mindset and build a truly strategic ESG capability.

Instead of scrambling to meet a deadline, you now have the time to:

  1. Implement Robust Data Systems: Move beyond spreadsheets and manual collection. Use this period to implement specialized software that can automate data collection from across your operations and value chain, ensuring your data is accurate, auditable, and ready for any request.

  2. Gain Actionable Insights: With a solid data foundation, you can move from simple reporting to generating powerful insights. Identify inefficiencies in your resource use, uncover hidden risks in your supply chain, and discover new opportunities for innovation.

  3. Build a Competitive Moat: By the time the revised regulations take full effect, your company can have a mature, efficient ESG management system in place. You will be ready to meet the demands of customers, investors, and regulators with ease, while your competitors are just beginning to scramble.

The question is no longer if your company will need to manage and report on its sustainability performance, but how. The companies that use this time wisely will not only ensure compliance but will also build more resilient, efficient, and valuable businesses for the future.


References

  1. Sodali: Breaking Down the Omnibus: Implications for the CSRD
  2. Trazable: The 5 ESG data points you should request from your suppliers
  3. Morgan Stanley: Morgan Stanley Sustainable Signals: Annual Global Survey...
  4. Deloitte Insights: Engaged employees are asking their leaders to take climate action

Your Value Chain, Your Problem: A Guide to Mastering ESG Data Under CSRD

· 6 min read
Tito Sala
Co-Founder EXO

Feeling the pressure of the CSRD's value chain requirements? You're not alone. The directive has fundamentally redefined corporate responsibility, making you accountable for the environmental and social impacts of your entire business ecosystem. For procurement, supply chain, and sustainability leaders, this presents the single biggest headache in ESG reporting: gathering reliable data from partners who are often unable, or unwilling, to provide it.

This isn't just another reporting exercise; it's a strategic imperative. But where do you even begin?

This guide cuts through the complexity. We'll break down exactly what the CSRD demands, diagnose the real-world challenges you're facing, and provide a clear, actionable framework to transform your supplier engagement from a transactional nightmare into a collaborative advantage.

The New Mandate: Why Your Supplier's Footprint is Now Yours

The Corporate Sustainability Reporting Directive (CSRD) is explicit: your reporting boundaries no longer end at your own factory gates. The rules require a comprehensive view of your value chain, which includes everyone from your upstream raw material suppliers to the downstream distributors and end-of-life partners who handle your products.

The trigger for this extensive reporting is the double materiality assessment. If you identify a material impact, risk, or opportunity (IRO) anywhere in your value chain—be it carbon emissions, water usage, or labor practices—you are now obligated to report on it. This creates a powerful "Responsibility Cascade" throughout the market.

The Responsibility Cascade

The CSRD turns large companies into engines of transparency. To meet your reporting needs, you must request ESG data from your suppliers. This creates a powerful commercial incentive that cascades the principles of sustainability down through the entire value chain, transforming the market for everyone.

The On-the-Ground Reality: A Deep-Tier Data Black Hole

While the mandate is clear, the reality is messy. There's a massive disconnect between the data you need and your partners' ability to provide it, creating a deep-tier "blind spot" where most risk resides.

The Supply Chain Visibility Cliff

Tier 1 Visibility: 60%

Most companies have a decent view of their direct suppliers.

Tier 2 Visibility: 15%

Visibility drops off sharply just one step down the chain.

Tier 3+ Visibility: 2%

Beyond Tier 2 lies a virtual data black hole, hiding significant risk.

This lack of visibility isn't just a reporting gap; it's a massive, unmanaged business risk.

The Proxy Paradox: A Tactical Solution but a Strategic Dead-End

Recognizing the difficulty of this task, regulators allow for the use of estimations and secondary data (proxies) when primary data is unobtainable. But this creates a paradox: what helps you comply in the short term may hinder your strategy in the long term.

Beware the Proxy Paradox

While using estimates is permissible for initial compliance, relying on them long-term is a strategic mistake. Generic, industry-average data is not specific enough to manage real risks or distinguish between high- and low-performing suppliers. It helps you file a report, but it doesn't help you run a better business.

Data Collection MethodologyAccuracyStrategic ValueBest For
Primary Supplier DataHighHighTargeted interventions, risk management, and driving real performance improvement.
Activity-Based EstimatesMediumMediumHotspot analysis and a more granular view than spend-based methods.
Spend-Based EstimatesLowLowEstablishing a complete, albeit imprecise, initial baseline with minimal data.

The true competitive advantage lies in building the capability to collect primary, supplier-specific data. This is what allows you to move from simply reporting to actively managing and improving your value chain's performance.

From Transaction to Transformation: Your Action Plan

Success requires a strategic shift: you must stop making transactional data requests and start building collaborative partnerships. This isn't about demanding data; it's about building shared capacity through a phased approach.

Phase 1: Prioritize & Segment (Months 1-3)

You can't boil the ocean. The first step is to focus your efforts for maximum impact. Key actions include mapping your value chain, segmenting suppliers by spend and risk, and forming a cross-functional internal team.

Phase 2: Communicate & Build Capacity (Months 4-12)

Move beyond the questionnaire. Proactively explain the "why" and help your partners succeed. Launch a pilot program with top suppliers, host educational webinars, and develop a collaborative Supplier Code of Conduct.

Phase 3: Incentivize & Collaborate (Months 13-18+)

Integrate ESG into your commercial relationships to drive real, lasting change. Embed ESG metrics into supplier scorecards, offer tangible rewards like preferred status, and launch joint innovation projects with sustainability leaders.

The Technology Imperative: Why Spreadsheets Will Fail You

The volume and complexity of value chain ESG data make manual systems untenable. Relying on a patchwork of emails and spreadsheets is inefficient, prone to error, and creates a data management nightmare that will never stand up to an audit.

Technology is the essential enabler. You need a platform designed to move you from chaotic data collection to structured, scalable supplier engagement.

Key Takeaways: Your Path to Mastering Value Chain Data

  • Responsibility is Redefined: The CSRD makes you accountable for the ESG performance of your entire value chain.
  • The Challenge is Real: A lack of deep-tier visibility and poor data quality are the biggest hurdles you face.
  • Collaboration Beats Transaction: Shift your approach from demanding data to building supplier capacity through education and incentives.
  • Proxies are a Stopgap, Not a Strategy: Use estimations to start, but your long-term goal must be to collect high-quality primary data.
  • Technology is Non-Negotiable: Manual processes will fail. You need a dedicated platform to manage data, engage suppliers, and ensure auditability.

Turn Your Biggest ESG Headache into a Competitive Advantage

A company cannot manage what it cannot measure, and that now includes its entire value chain. The chaos of chasing suppliers for inconsistent data in disparate spreadsheets is a high-risk, low-reward activity. It's time for a new approach.

Our platform provides the integrated solution you need. With a dedicated supplier engagement portal, you can streamline data requests, automate reminders, and provide your partners with the tools they need to report accurately. The platform integrates supplier-provided data directly into your overall ESG performance dashboard, turning a chaotic process into a structured, manageable, and auditable one.

Stop chasing data. Start building a more resilient and sustainable value chain.