“Please provide the site’s annual electricity consumption” sounds like a clear request. It may produce a building total, the company’s share of that total, a utility invoice covering different dates or a figure estimated from expenditure.
Each response can look plausible in a completed spreadsheet. The difficulty appears when the reporting team tries to explain what the number represents.
What is ESRS?
ESRS (European Sustainability Reporting Standards) set out how companies subject to the EU’s Corporate Sustainability Reporting Directive (CSRD) report sustainability information. They cover a company’s impacts on people and the environment, as well as sustainability-related risks and opportunities. For a reporting team, the standards provide the starting point for deciding which disclosures apply and what information must be collected to support them.
What is ESRS Data Collection?
ESRS data collection is the process of obtaining and supporting the information needed for disclosures under the European Sustainability Reporting Standards. It includes numerical measures and narrative claims. Its practical purpose is to produce information that fits the disclosure and can be examined without reconstructing the preparer’s assumptions.
Core Requirements for Reproducible ESRS Data
Reproducible data allows a reviewer to see where a reported value came from, how it was calculated and which version was approved. The following elements help preserve that trail from the initial request through to the final disclosure:
- Metadata Tagging
- Calculation Lineage
- Version Control
- Proxy and Estimate Documentation
- Structured Evidence Packs
Common ESRS Data Collection Pitfalls to Avoid
A completed field does not always contain a usable answer. Common pitfalls include collecting a figure before defining its reporting boundary, treating an estimate as a measured value, and accepting a source document without recording how it supports the reported amount. Narrative claims can create the same problem when the wording describes broader implementation than the evidence shows. Clear definitions, documented methods and review of the supporting records help catch these gaps before they reach the disclosure.
How to Collect Information Under the ESRS?
Step 1: Define the Disclosure and Its Boundary
The collection list should follow the applicable standards and the company’s materiality assessment. A datapoint appearing in a reference document does not, by itself, establish that every company must collect it. EFRAG’s implementation guidance provides material on materiality, the value chain and datapoints; it does not replace the legally applicable standards.
Agree the population before requesting a value. Which entities, sites or activities are included? What period does the disclosure cover? What method governs allocation or estimation? Local owners need those decisions in language they can use.
The CSRD scope assessment establishes the reporting obligation. ESRS collection translates that obligation into answerable requests. Keeping the two connected prevents a team from maintaining an old questionnaire after the underlying requirement has changed.
Step 2: Map Datapoints to the Applicable ESRS Standards
For each required disclosure, identify the information needed to support it and link each request to the relevant ESRS requirement. Record whether the request calls for a numerical value, an explanation or both. This gives local owners a clear reason for providing the information and helps the reporting team spot gaps or duplicate requests before collection begins.
Step 3: Assign Data Owners and Responsibilities
Assign an owner for each request based on who can access and explain the underlying records. Separate the roles of providing data, reviewing its method and approving the value for disclosure. Where a figure depends on several teams, name one person to coordinate the answer and resolve gaps before submission.
Step 4: Set Up Collection Templates and a Timeline
Give owners a consistent template that asks for the value or claim, reporting period, unit, boundary, source and method. Include fields for estimates, missing information and review comments so those details are visible from the start. Set deadlines for submission, review and correction separately; a single final due date leaves little time to resolve conflicting answers.
Step 5: Collect Value Chain Data from Suppliers
Where an applicable disclosure requires value chain information, ask suppliers for the specific data needed, with clear definitions, periods and units. Record which supplier provided each response, the source or method behind it, and any gaps or estimates. If information cannot be obtained, document the request and assess how to address the gap under the applicable ESRS requirements.
Step 6: Separate Source Data from Reported Values – A Worked ESRS Example
Consider an illustrative shared warehouse with annual electricity consumption of 600 MWh. Assume the company’s reporting boundary covers its own operations there, and reliable submeter records support a 360 MWh figure for those operations.
The utility invoice supports the building total. The submeter records support the company’s consumption. The reporting team still needs to confirm that the period and boundary match the disclosure and that the chosen method is appropriate.
Entering 600 MWh because it appears on the invoice would include consumption outside the assumed boundary. Dividing the total in half because two occupiers share the building would introduce a different, unsupported basis. The supported 360 MWh answer depends on the relationship between the records.
Retain that relationship in the collection entry. The reviewer should be able to open the building record, inspect the submeter evidence and understand how the reported amount was selected. A single attachment marked “electricity evidence” provides less help.
| Collection detail | What it establishes in the example |
|---|---|
| Reporting boundary | The company’s operations within the shared warehouse |
| Period and unit | The stated annual period measured in MWh |
| Source records | Building consumption and relevant submeter readings |
| Reported value | 360 MWh under the stated assumptions |
| Review question | Whether the records and method support that boundary and period |
This is an operating example, not a prescribed ESRS calculation template. Its purpose is to show why a source value may require interpretation before it becomes a disclosure value.
Step 7: Record Missing Data and Estimates Transparently
If a submeter record is missing, the owner should be able to record that fact. An empty field should not quietly become zero. Nor should an estimate become indistinguishable from a measured value once the entry is submitted.
Where an estimate is appropriate under the applicable requirements, document its method and limitations. If the reporting boundary remains unsettled, route the issue to someone authorised to decide it. Asking the site to resubmit the same source does not answer a central reporting question.
Completion measures should reflect these distinctions. Submitted means that information has arrived. Reviewed means that specified checks have been performed. Approved means that an authorised person has accepted a particular version. Treating them as synonyms can make the dashboard look further advanced than the work.
Management needs to see which unresolved entries affect significant disclosures, who owns them and what would allow the work to proceed. Routine completed fields should not conceal a missing decision.
Step 8: Support Narrative Claims in ESRS Reporting with Evidence
A policy document can establish that a policy exists. It may not establish that the policy has been implemented at every location described in the report.
Suppose a training programme has been completed at two sites and scheduled at four others. The supporting record should preserve those different stages. A polished paragraph describing a completed group-wide programme would go beyond the evidence.
Ask the policy owner to confirm the actual coverage and effective dates. Connect the draft wording to those confirmations. A reviewer should be able to identify the factual basis of terms such as implemented, completed and all sites.
AI can help organise approved source material or draft a passage for review. The person accepting the wording must still check whether qualifications disappeared during drafting. Shorter prose can accidentally turn a limited claim into a broader one.
Step 9: Consolidate Site Data at Group Level
Before combining site submissions, check that they use the same reporting period, units and group boundary. Resolve overlaps, omissions and differences in calculation methods, recording any conversions or adjustments. Keep a link from each group total to the site entries behind it so a reviewer can reproduce the consolidated figure and trace later corrections.
Step 10: Carry Corrections and ESRS Updates Through to Disclosures
Return to the warehouse example. If a source correction changes the supported consumption, the collection system should identify the disclosure value that used it. The owner can then assess the calculation, explain the movement and route the revised result for review where required.
Preserve the earlier source and accepted version. Otherwise, a later reviewer may see the new figure but have no way to understand why the previously published amount differed.
The same discipline applies when standards change. The Commission’s July 2026 announcement on revised ESRS describes adoption and subsequent scrutiny. Collection teams should establish applicability and identify the actual requests affected, rather than replacing an entire workbook solely because a new version exists.
Shared entity and site records can reduce repeated collection work across finance, tax and sustainability. Each use still needs its own mapping. Reusing an invoice does not mean that its monetary amount can substitute for a physical measure.
Step 11: Test Your ESRS Data Before the Reporting Deadline
Choose one significant disclosure and give its collection record to a qualified colleague who did not prepare it. Ask that person to reproduce the answer using the recorded sources and method.
Where the colleague stops, identify the missing item: an unclear boundary, an inaccessible source, a conversion with no basis or an unresolved review comment. Each finding should become a specific correction to the request or workflow.
The warehouse entry is ready when the next reviewer can explain why the reported figure is 360 MWh, which records support it and what would cause it to change. That is a useful standard for the rest of the collection programme.
