# CSRD Compliance Programme Reference

## Programme Templates, Checklists, and Implementation Guidance

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## 1. CSRD Implementation Roadmap

### Phase 0 — Scoping (Months 1–2)
- [ ] Confirm in-scope status: check size thresholds (employees, turnover, assets), listing status, PIE status
- [ ] Determine first mandatory reporting year (FY 2024, 2025, 2026, or 2028)
- [ ] Identify group structure: parent, subsidiaries; check if subsidiary can rely on group CSRD report
- [ ] Assess non-EU company obligations if applicable (>€150M EU turnover)
- [ ] Identify existing ESG reporting: GRI, TCFD, CDP, SASB, NFRD — baseline assessment

### Phase 1 — Foundation (Months 2–5)
- [ ] Appoint CSRD project lead and cross-functional team (Finance, Legal, Sustainability, HR, Risk)
- [ ] Establish governance: board/committee oversight of CSRD preparation
- [ ] Engage external advisors: CSRD consultant, assurance provider (early engagement recommended)
- [ ] Conduct preliminary Double Materiality Assessment (DMA) — identify material ESRS topics
- [ ] Map existing disclosures to ESRS datapoints — identify gaps
- [ ] Assess data availability across all material ESRS topics

### Phase 2 — Gap Assessment and Planning (Months 4–8)
- [ ] Complete full DMA with stakeholder engagement
- [ ] Document DMA methodology and outputs (ESRS 2 IRO-1 / SBM-3)
- [ ] Conduct detailed gap assessment: required datapoints vs. data available
- [ ] Assess value chain data collection feasibility for material topics
- [ ] Evaluate IT/systems requirements: data collection, aggregation, reporting systems
- [ ] Design data collection processes and assign ownership
- [ ] Plan Scope 3 GHG emissions programme (if E1 material)
- [ ] Engage assurance provider: agree scope, approach, timeline for limited assurance

### Phase 3 — Data Collection and Controls (Months 6–14)
- [ ] Implement data collection processes for all material ESRS datapoints
- [ ] Develop and implement internal controls over sustainability reporting
- [ ] Establish data quality review and sign-off procedures
- [ ] Collect and verify Scope 1, 2, 3 GHG emissions data
- [ ] Collect workforce data (ESRS S1 datapoints)
- [ ] Implement value chain data collection: supplier questionnaires, CDP, proxy data
- [ ] Develop transition plan (ESRS E1-1) if climate is material
- [ ] Conduct scenario analysis for climate risks/opportunities (ESRS E1-9)

### Phase 4 — Drafting and Assurance (Months 12–18 from first reporting year)
- [ ] Draft CSRD disclosures for all material ESRS topics
- [ ] Ensure dedicated section in management report (Accounting Directive Art. 19a)
- [ ] Apply XBRL/iXBRL digital tagging to sustainability disclosures (ESEF taxonomy)
- [ ] Internal review: legal, finance, sustainability, board review of disclosures
- [ ] Engage assurance provider for limited assurance engagement
- [ ] Respond to assurance queries and implement recommendations
- [ ] Obtain assurance report
- [ ] Board / supervisory body sign-off

### Phase 5 — Publication and Ongoing Compliance
- [ ] Publish sustainability disclosures in annual report
- [ ] File ESEF-tagged annual report with national registry
- [ ] Update DMA annually
- [ ] Track ESRS amendments and Commission guidance
- [ ] Monitor Omnibus Package simplifications (post-2025 legislative changes)
- [ ] Begin preparation for reasonable assurance (phased in post-2028)

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## 2. CSRD Gap Assessment Template

### Instructions
Complete this table after DMA. For each material ESRS topic, assess current data availability and identify gaps requiring action before first reporting year.

| ESRS | Disclosure | Required Datapoint | Current State | Gap | Priority | Action Required | Owner | Target Date |
|------|-----------|-------------------|--------------|-----|---------|----------------|-------|------------|
| ESRS 2 | GOV-1 | Board sustainability oversight | Partial — board reviews ESG quarterly | Missing: expertise credentials, time spent | HIGH | Document board ESG discussion records; collect CV/bio data | Company Secretary | Q2 2025 |
| ESRS 2 | GOV-3 | Sustainability in incentive schemes | No ESG KPIs in remuneration | Gap: no linkage | HIGH | Board Remuneration Committee to design ESG KPIs | CHRO + Board RemCo | Q1 2025 |
| ESRS 2 | SBM-3 | DMA output — material IROs | DMA not conducted | Critical gap | CRITICAL | Conduct DMA with stakeholder engagement | Sustainability team | Q3 2024 |
| E1 | E1-6 | Scope 1, 2, 3 GHG emissions | Scope 1+2 available; Scope 3 not measured | Scope 3 all 15 categories missing | CRITICAL | Implement Scope 3 measurement programme | Operations + Procurement | Q1 2025 |
| E1 | E1-1 | Climate transition plan | No formal plan | Full gap | HIGH | Develop transition plan aligned with SBTi/Paris | CEO + Strategy | Q2 2025 |
| S1 | S1-16 | Gender pay gap | Partial HR data | Missing: median pay by gender | HIGH | Commission pay analysis; align with EU Pay Transparency Dir. | CHRO | Q3 2025 |
| S1 | S1-14 | LTIFR (lost time injury rate) | Available for own employees | Missing: contractor data | MEDIUM | Extend H&S data collection to contractors | EHS Manager | Q4 2025 |
| G1 | G1-3 | Anti-corruption training coverage | 60% employees trained | Missing: updated coverage data; need >80% | MEDIUM | Run annual anti-corruption training campaign | Legal/Compliance | Q2 2025 |

**Priority Definitions:**
- **CRITICAL:** Legal requirement; cannot publish without this data
- **HIGH:** Material gap; will result in qualified assurance if not resolved
- **MEDIUM:** Gap exists; resolution improves quality but limited assurance achievable
- **LOW:** Enhancement opportunity; not essential for first-year compliance

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## 3. Data Collection Framework

### Governance Data (ESRS 2 GOV)

| Datapoint | Data Source | Frequency | Owner |
|-----------|------------|-----------|-------|
| Board member sustainability expertise | Board CVs / biography | Annual | Company Secretary |
| Board ESG agenda items / time spent | Board meeting minutes | Annual | Company Secretary |
| ESG KPIs in executive remuneration | RemCo decisions / contracts | Annual | CHRO / Legal |
| Due diligence process coverage | Procurement / Legal | Annual | Legal |

### Climate Data (ESRS E1)

| Datapoint | Data Source | Frequency | Owner |
|-----------|------------|-----------|-------|
| Scope 1 emissions | Fuel consumption records, fleet data | Monthly → Annual | Facilities / Fleet |
| Scope 2 (location-based) | Electricity invoices + IEA grid factors | Monthly → Annual | Finance / Facilities |
| Scope 2 (market-based) | Energy certificates (RECs, GOs, PPAs) | Annual | Energy Procurement |
| Scope 3 Cat. 1 (purchased goods) | Supplier spend × emission factors (EPA/ecoinvent) | Annual | Procurement |
| Scope 3 Cat. 3 (fuel & energy) | Calculated from S1+S2 data | Annual | Facilities |
| Scope 3 Cat. 6 (business travel) | Travel management system | Annual | HR / Travel |
| Scope 3 Cat. 7 (commuting) | Employee survey / commuting patterns | Annual | HR |
| Scope 3 Cat. 11 (product use) | Product emission factors + sales data | Annual | Product team |
| Scope 3 Cat. 12 (end-of-life) | Waste management data + product specs | Annual | Product team |
| Energy consumption total | All energy bills / smart metering | Monthly → Annual | Facilities |
| Renewable energy share | Energy purchase contracts / guarantees of origin | Annual | Energy Procurement |

### Workforce Data (ESRS S1)

| Datapoint | Data Source | Frequency | Owner |
|-----------|------------|-----------|-------|
| Headcount by gender / contract type | HRIS system | Monthly → Annual | HR |
| Turnover rate | HRIS system | Annual | HR |
| Gender pay gap (median) | Payroll system analysis | Annual | HR / Finance |
| Collective bargaining coverage | HR records / legal | Annual | HR |
| LTIFR, fatalities | EHS / incident management system | Monthly → Annual | EHS |
| Training hours per employee | LMS (Learning Management System) | Annual | L&D |
| Parental leave uptake | HR records | Annual | HR |
| CEO pay ratio | Remuneration disclosures / payroll | Annual | Finance / HR |

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## 4. Scope 3 GHG Emissions Programme

### Category Priority Matrix

| Category | Typically Material? | Data Availability | Recommended Approach |
|----------|-------------------|------------------|---------------------|
| Cat. 1: Purchased goods & services | Yes (for most) | Low-Medium | Spend-based with EEIO factors → supplier surveys for key items |
| Cat. 2: Capital goods | Medium | Medium | Asset registry × emission factors |
| Cat. 3: Fuel & energy (upstream) | Yes | High | Calculate from S1+S2 using GHG Protocol factors |
| Cat. 4: Upstream transport | Medium | Low | Tonne-km × emission factors; freight invoices |
| Cat. 5: Waste in operations | Low-Medium | Medium | Waste management invoices |
| Cat. 6: Business travel | Medium | High | Travel management system data |
| Cat. 7: Employee commuting | Medium | Low | Annual employee survey |
| Cat. 8: Upstream leased assets | Sector-specific | Medium | Lease registry |
| Cat. 9: Downstream transport | Sector-specific | Low | Distribution data |
| Cat. 10: Processing of sold products | Sector-specific | Low | Industry averages |
| Cat. 11: Use of sold products | Yes (for manufacturers) | Medium-High | Product emission factors × sales volume |
| Cat. 12: End-of-life treatment | Medium | Low | Industry averages; waste composition |
| Cat. 13: Downstream leased assets | Sector-specific | Low | Lease register |
| Cat. 14: Franchises | Sector-specific | Low | Franchise data collection |
| Cat. 15: Investments | Sector-specific (financial) | Medium | PCAF methodology |

**Recommended Scope 3 Phasing:**
- **Year 1:** Cats. 1, 3, 6, 7, 11 (typically 80%+ of emissions)
- **Year 2:** Add Cats. 2, 4, 5, 12
- **Year 3:** Full coverage with improved primary data

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## 5. Assurance Readiness Checklist

### Pre-Assurance Requirements

**Governance and Responsibility**
- [ ] Named individual responsible for each material ESRS topic and its data
- [ ] Clear escalation path for sustainability data queries
- [ ] Board/audit committee oversight of sustainability reporting

**Documentation**
- [ ] DMA documented with methodology, scoring, stakeholder inputs
- [ ] Data collection procedures documented for each datapoint
- [ ] Calculation methodology documented (GHG Protocol, ESRS guidance)
- [ ] Internal review and sign-off process documented
- [ ] Correction procedure for sustainability data errors

**Data Quality**
- [ ] Data trail from source system to reported figure for each datapoint
- [ ] Evidence of data completeness checks (coverage of operations)
- [ ] Prior year comparatives available and reconciled
- [ ] Estimation methodology documented for gaps (proxy data, interpolation)
- [ ] Restatement policy defined

**Controls**
- [ ] Internal controls documented for key sustainability data processes
- [ ] Evidence of management review and approval of sustainability disclosures
- [ ] Segregation of duties between data collectors and approvers

**Boundary and Scope**
- [ ] Reporting boundary clearly defined (consolidation approach: financial control, operational control, equity share)
- [ ] Any boundary differences vs. financial reporting documented and justified
- [ ] Value chain scope clearly defined and disclosed

### Limited Assurance vs. Reasonable Assurance

| Aspect | Limited Assurance (Current) | Reasonable Assurance (Future) |
|--------|----------------------------|------------------------------|
| Standard | ISAE 3000 (Revised) | ISAE 3000 (Revised) — higher standard |
| Procedures | Inquiries + analytical procedures | As above + substantive testing |
| Evidence | Less extensive | More extensive; site visits typical |
| Conclusion | "Nothing came to our attention" | "The information is fairly presented" |
| Documentation | Less detailed | Detailed audit-like evidence file |
| Timeline | CSRD Phase 1 (now) | Commission review by 2028 |

**Practical Tip:** Build reasonable assurance-quality documentation from day one — retroactively improving evidence trails is very difficult and expensive.

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## 6. XBRL Digital Tagging — Practical Guide

### What Must Be Tagged
- All quantitative datapoints in the sustainability disclosures
- Key qualitative disclosures (policy statements, targets)
- Taxonomy: European Single Electronic Format (ESEF) extended with CSRD sustainability taxonomy

### Tagging Approach Options
1. **Software-integrated:** Sustainability reporting software with built-in XBRL tagging (SAP Sustainability Footprint Management, Workiva, Sweep, etc.)
2. **Post-report tagging:** Tag the final report using ESEF tagging tools
3. **Outsourced:** Use XBRL tagging service provider

### Timeline
- ESEF sustainability taxonomy: Commission in development (consult ESMA for latest timeline)
- First XBRL-tagged sustainability reports: aligned with first CSRD reporting year

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## 7. Value Chain Data Collection — Supplier Engagement

### Supplier Prioritisation Framework

Prioritise suppliers based on:
1. **Spend-based emissions significance** (Cat. 1 Scope 3 contribution)
2. **High-risk sectors** (garments, electronics, agriculture, extractives)
3. **High-risk geographies** (countries with elevated labour/environmental risks)
4. **Strategic / sole-source relationships** (limited substitutability)

### Data Collection Methods

| Method | Best for | Effort | Data Quality |
|--------|---------|--------|-------------|
| CDP Supply Chain | Large, listed suppliers | Low (for company) | High |
| Supplier questionnaire (EcoVadis, custom) | Tier-1 suppliers | Medium | Medium-High |
| Spend-based emission factors (EEIO) | Long-tail suppliers | Very low | Low-Medium |
| Industry sector averages | Where direct data unavailable | Very low | Low |
| Site audits | High-risk suppliers | High | Very High |

### Disclosure of Estimation Approaches (ESRS 1, para. 64)
Where value chain data is not directly available, companies must disclose:
- Which datapoints use estimated/proxy data
- The estimation methodology applied
- The level of accuracy and main sources of uncertainty
- Steps being taken to improve data quality over time

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## 8. CSRD vs. NFRD — Key Differences

| Aspect | NFRD (old) | CSRD (new) |
|--------|-----------|-----------|
| Companies in scope | ~11,000 (PIEs >500 employees) | ~50,000 (all large + listed SMEs) |
| Non-EU companies | Not covered | >€150M EU turnover |
| Standards | No mandatory standards | Mandatory ESRS |
| Materiality | Financial only | Double materiality (impact + financial) |
| Value chain | Not required | Required where material |
| Assurance | Not required (some member states) | Mandatory limited assurance |
| Digital tagging | Not required | XBRL/iXBRL mandatory |
| Location | Flexible (separate report allowed) | Dedicated section of management report |

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## 9. Omnibus Package Watch (2025)

The European Commission proposed CSRD simplifications in the "Omnibus Package" (February 2025):

**Proposed changes (not yet final as of ESRS publication date):**
- Narrowing scope: may raise employee threshold to 1,000 (from 250)
- Reducing mandatory datapoints
- Delaying listed SME obligations
- Simplifying value chain reporting requirements

**Important:** Always verify the current legislative status before advising clients on scope and datapoint requirements. Check EUR-Lex and the European Commission website for latest developments.

The underlying ESRS standards issued under Commission Delegated Regulation (EU) 2023/2772 remain the definitive source until amended.