Unpacking

CSRD:
A Guide for Business
Unpacking CSRD: A Guide for Business 2

Disclaimer: This guide is for information purposes only and is correct at date of
publication but may be subject to change thereafter. Ibec and Davy assume no
responsibility for any use to which the information may be put, or for any errors.
The information in the guide is not intended to be a substitute for legal advice,
where appropriate.

Please note that the provision of this product or service does not require licensing,
authorisation, or registration with the Central Bank of Ireland and, as a result, is not
covered by the Central Bank of Ireland’s requirements designed to protect consumers
or by a statutory compensation scheme.

October 2024
Contents
Foreword from Danny McCoy, CEO, Ibec 3
Foreword from Dr. Dorothy Maxwell, Head of Sustainability & ESG advisory, Davy Horizons 4
Glossary and Acronyms 5
1. Executive Summary 9
Navigation of Toolkit Contents 10
2. Demystifying CSRD 12
2.1 What is CSRD? 12
2.2 Application and Timeline 15
2.3 Companies in Scope by Sector and Size 16
2.4 Wider Context – SFDR, EU Taxonomy and CSDDD 19
2.5 CSRD and International Reporting Regimes 21
3. ESRS Standards Playbook 26
3.1 ESRS Standards 26
3.2 Topics, Subtopics and Sustainability Matters 29
3.3 Value Chain 29
3.4 Assurance 29
3.5 Digital Data Tagging 34
3.6 Sectoral Standards 35
4. CSRD Implementation 37
4.1 Compliance Roadmap 37
4.2 Double Materiality Assessment 38
4.3 Stakeholder Engagement 43
4.4 CSRD Gap Analysis 46
4.5 Double Materiality Matrix and Results Analysis 47
4.6 Sustainability Statement 52
5. Impact, Risk and Opportunity Assessment 55
5.1 Commencing an Assessment 55
5.2 Risk Identification and Assessment 55
5.3 Highlighting Opportunities 56
6. Topics and Datapoints for Disclosure 60
6.1 ESRS topics and sub-topics 60
6.2 Datapoints 62
6.3 Datapoint Examples 63
7. Grants and Financial Supports 66
7.1 Grants and Financial Supports available for Green Business Initiatives 66
7.2 Other helpful tools 67
8. Further Resources 69
Unpacking CSRD: A Guide for Business 2

About Ibec
Ibec is Ireland’s largest lobby and business representative group. Our purpose is to help
build a better, sustainable future by influencing, supporting and delivering for business
success. With over 300 employees, Ibec engages with key stakeholders in Ireland and
internationally through our six regional offices and our Brussels office, along with an
extensive international network in the UK and US.

Ibec positions are shaped by our diverse membership, which range from small to large,
domestic to multinational, and our 39 trade associations cover a wide range of industry
sectors.

As well as lobbying, Ibec provides a wide range of professional services and

management training to members on all aspects of human resource management,
occupational health and safety, employee relations and employment law.

www.ibec.ie

About Davy Horizons

Davy Horizons is the sustainability consultancy within Davy Group, offering world-class
expertise in sustainability services across strategy, implementation, policy and reporting.
They work with business, government and not-for-profits across all sectors of the
economy and are subject matter experts across Environmental, Social and Governance
(ESG) issues.

Operating as a trusted adviser, the team support organisations to implement bespoke

sustainability solutions to drive long-term success. Davy Horizons are thought leaders
on sustainability, publishing insights and running events on key sustainability and ESG
trends drawing on an extensive international network of experts.

www.davy.ie/horizons or email [email protected]

Intended Audience:

• This is aimed at corporates in scope of CSRD or in the value chain of corporates

that are.

• The function in a corporation overseeing sustainability integration and reporting

including the Chief Sustainability Officer, Head of Sustainability, Company Secretary,
CEO, CFO or General Manager.

This content is provided for general information purposes and is not intended to be used in place of
consultation with professional advisors. This document refers to marks owned by third parties. All such third-
party marks are the property of their respective owners. No sponsorship, endorsement or approval of this
content by the owners of such marks is intended, expressed or implied.

All rights reserved. Davy Horizons and its logo are registered trademarks of Davy Group. Copyright © 2024
Davy and Ibec
Unpacking CSRD: A Guide for Business 3

Foreword from Danny McCoy,

CEO, Ibec
Corporate sustainability has evolved in recent years from being an optional consideration to
a strategic business imperative, consistently top of mind for executives and boards. Once
largely focused on environmental compliance, it now encompasses how organisations
achieve a balance between core operations and their impact on people and planet.

Companies are looking at how they do business in a way that delivers economic success
but that is also ethical and responsible, protects the environment, and helps society
thrive. The Corporate Sustainability Reporting Directive (CSRD) stands as a critical
framework guiding organisations towards greater transparency and accountability.

The CSRD seeks to ensure that business provides clear, comparable and reliable
information on their environmental, social and governance (ESG) impacts. This
transparency is key for investors, stakeholders and the broader society and will enable
informed decision-making while fostering trust in corporate practices.

Many businesses have been embracing sustainability and making it a mainstream

strategic priority for their organisation, recognising that investment, talent, and
consumers will increasingly flow to businesses that champion the interests of
stakeholders as well as shareholders. It is no longer about avoiding fines or complying
with new regulations but rather embracing responsibility that can create greater business
value over time.

Ibec recognises the potential of the CSRD to drive positive change and foster a culture
of sustainability within the business community. However, this undertaking is complex
requiring a significant commitment of time, people and capital to capture and report the
necessary data and processes. To support our members in achieving these goals Ibec
has partnered with Davy Horizons to share their expertise on this toolkit project, to assist
business to not only comply but thrive in this new landscape. Several Ibec members
have provided contributions to the toolkit that help illustrate their CSRD journey with
actionable insights.

This toolkit serves as a comprehensive resource for understanding and implementing the
CSRD requirements. It offers valuable insights and guidance for both the organisation in
scope looking to refine their reporting practices, as well as the small enterprise beginning
their sustainability journey who may not be in scope directly but is in the supply chain of
an organisation that is.

By harnessing the challenge of CSRD we can turn compliance into a strategic advantage,
showcase our leadership in responsible business practices, and contribute to the broader
goals of the EU Green Deal and the United Nations Sustainable Development Goals. This
is an opportunity to lead with purpose and drive meaningful change for our communities,
our economy and our planet.
Unpacking CSRD: A Guide for Business 4

Foreword from Dr. Dorothy

Maxwell, Head of Sustainability &
ESG Advisory, Davy Horizons
The Corporate Sustainability Reporting Directive (CSRD) modernises sustainability reporting
in business, making Non-Financial Environmental, Social and Governance (ESG) information
as important and regulated as financial reporting has been for over a hundred years. This
reflects the importance of sustainability to managing a company’s business performance and
supporting long term success.

CSRD phases in from 2024 and will be an uplift for most businesses, even those who already
publish a Sustainability Report. It integrates ESG information into management reporting
through a ‘Sustainability Statement’ with detailed disclosure and datapoint requirements. This
covers mandatory and material ESG and financial information to ensure company impacts,
risks and opportunities are suitably managed over the short, medium, and long term. It
also requires assurance of data – initially to a ‘limited assurance’ level - to improve quality,
comparability and to avoid greenwash.

The good news is that while the changes in mandatory reporting that CSRD will bring will
be complex for businesses to navigate, it ultimately will bring clarity as will the consolidation
across a range of reporting standards and requirements. Better ESG data released into the
public domain will enable stakeholders including investors, customers, and lenders, to make
better decisions to support a low carbon and sustainable market transformation. It will also
support companies to unlock opportunities and new markets in the green economy.

Due to the scale of the changes and data required, preparation in advance of the compliance
timeline is essential to get ready. We advise starting early and taking plenty of time to
determine what is required for your business.

It is with this in mind that we at Davy Horizons are proud to collaborate with Ibec on this CSRD
guide for business. The aim of this guidance is to provide an accessible and concise guide for
business to support preparing for reporting under the CSRD.

It provides clarity on what CSRD is, how to comply and avail of the benefits credible and
effective sustainability reporting brings. It incorporates nuanced explanations, case studies to
illustrate from practice, and clear, actionable steps for compliance along with a roadmap and
signposts to resources to facilitate implementation.
Unpacking CSRD: A Guide for Business 5

Glossary and Acronyms

Abbreviation/ Definition Abbreviation/ Definition
Term Term

CapEx Capital expenditures - CapEx are DNSH Do No Significant Harm - For activities
funds used by a company to acquire, to qualify as sustainable under the EU
upgrade, and maintain physical assets Taxonomy regulation they must make
such as property, plants, buildings, a substantial contribution to one of the
technology, or equipment. six defined objectives and must do no
significant harm to the others.
CDP Formerly the Carbon Disclosure Project
- CDP operates a global environmental Double Double Materiality (DM) is required
disclosure and rating system for Materiality by CSRD to determine disclosures
investors, companies, cities, states and material for reporting. This is based on
regions to manage their environmental how the company’s activities impact
impacts, including greenhouse the environment and people, as well as
gas (GHG) emissions, forest risk the company’s financial performance.
commodities, and water security in
their supply chains. EFRAG European Financial Reporting Advisory
Group - EFRAG was established by
CE Circular Economy - The Circular the European Union (EU) and the
Economy is a model of production and private sector to provide technical
consumption, which involves sharing, advice to the European Commission on
leasing, reusing, repairing, refurbishing accounting matters. Under the CSRD,
and recycling existing materials and EFRAG oversee the Sustainability
products for as long as possible. Reporting Standards (ESRS) defining
the CSRD disclosure requirements and
CO2e Carbon dioxide equivalent - The associated guidance.
standard unit used to compare and
account for GHG emissions based on ESG ESG stands for Environmental, Social,
their Global Warming Potential. and Governance, and it represents a
framework for assessing a company's
CSDDD Corporate Sustainability Due Diligence impact on the environment, its social
Directive - The EU Corporate responsibilities, and the quality of its
Sustainability Due Diligence Directive corporate governance.
will require companies to identify,
prevent or mitigate adverse impacts of EU The EU Taxonomy is a classification
their activities on human rights and the Taxonomy system to define environmentally
environment. sustainable economic activities. It
aims to provide businesses, investors,
CSRD Corporate Sustainability Reporting and policymakers with a common
Directive - The Corporate Sustainability framework to identify activities
Reporting Directive will require all listed that contribute substantially to
PLCs, large companies and SMEs to environmental objectives (e.g. climate
disclose detailed key performance change mitigation, the transition to a
information across a range of circular economy, pollution prevention,
environmental, social and governance and biodiversity conservation.)
factors, all of which should be certified.
GBP Green Bond Principles - The Green
Digital Data Digital data tagging involves labelling Bond Principles are a set of voluntary
Tagging data within digital documents frameworks to promote transparency
using specific codes to make the and best practice when issuing bonds
information machine-readable and with social or environmental objectives.
easily accessible. This is done through
the Extensible Business Reporting
Language (XBRL), a standardised
language for exchanging business
information.
Unpacking CSRD: A Guide for Business 6

Abbreviation/ Definition Abbreviation/ Definition

Term Term

GHG Greenhouse Gas Emissions - GHG IFRS-TCFD Taskforce on Climate-related Financial

Emissions emissions include carbon dioxide, Disclosures - The Financial Stability
methane, nitrous oxide and others. Board’s TCFD has developed
The GHG Protocol categorises them guidelines that define the information
as scope 1 – direct and controlled by that companies should disclose when
a company, scope 2 - indirect arising assessing climate finance risks. This
from purchased electricity, steam, includes the material transitional and
heating and cooling consumed by the physical risks to the business from
reporting company and scope 3 – all climate change.
other indirect emissions, e.g. up/down
stream in the value chain. IPCC Intergovernmental Panel on Climate
Change - The IPCC is the United
Greenwashing Consumers can be misled, and Nations body for assessing the
companies can give a false impression science related to climate change,
of their environmental impacts or climate change mitigation options
benefits – a practice known as and adaptation steps to deal with
greenwashing the impacts from climate change. It
issues reports periodically, including a
GRI Global Reporting Initiative - GRI has summary for policymakers.
developed a comprehensive set of
standards for voluntary sustainability IROs Impacts, Risks and Opportunities –
reporting. CSRD reporting is focused on driving
disclosure that shows how IROs
GWP Global Warming Potential - GWP associated with business operations
compares the impact of different gases and the value chain are managed over
on global warming and is used in GHG the short, medium and long term.
accounting. It is a measure of how
much energy the emissions of 1 tonne ISO International Organisation for
of a gas will absorb over a given period Standardisation - The ISO develops
of time (usually 100 years), relative to guidance and standards for
the emissions of 1 tonne of Carbon organisations to manage a number of
Dioxide (CO2). The larger the GWP, the performance areas, including quality,
more that a given gas warms the Earth energy, environment, social and others.
compared to CO2 over that time period.
ISSB International Sustainability Standards
IFRS International Financial Reporting Board - Part of the IFRS, the ISSB
Standards - The IFRS Foundation is an delivers international sustainability
international organisation overseeing related disclosure standards for
the international sustainability reporting companies.
standards IFRS S1 Climate Disclosure,
IFRS S2 Sustainability Disclosure, LCA Lifecycle Assessment - A method for
plus associated guidance. The IFRS measuring the environmental impacts
International Sustainability Standards across the value chain of products,
Board (ISSB) develops these standards. aligned to ISO14044 and ISO14048
LCA standards.
IFRS-SASB Sustainability Accounting Standards
Board (SASB) – The SASB is a non- Net Zero Achieving Net Zero GHG Emissions for a
profit organisation that creates and corporate means that all GHG emissions
maintains industry-specific standards produced in 1 year can be removed from
that guide companies' disclosure the atmosphere by natural or artificial sinks.
of financially material sustainability Alignment to the SBTi Net Zero standard
information to investors and other defines what this requires and is the
financial stakeholders. credible way for corporates to achieve this.

NF Non-Financial
Unpacking CSRD: A Guide for Business 7

Abbreviation/ Definition Abbreviation/ Definition

Term Term

NFRD Non-Financial Reporting Directive – The UNGC United Nations Global Compact - The
NFRD legally defined the reporting of non- UN Global Compact is an initiative for
financial key figures for EU companies and companies to align their strategies and
was adopted in 2014. It will be gradually operations with 10 universal principles
replaced by the CSRD in 2024. related to human rights, labour,
environment and anti-corruption, and take
OpEx Operating expenses - OpEx is an expense actions that advance societal goals and the
that a business incurs through its normal implementation of the SDGs.
business operations that include rent,
equipment, inventory costs, marketing, UN PRI United Nations Principles of Responsible
payroll, insurance, and funds allocated for Investment - Principles for Responsible
research and development. Investment is a United Nations supported
international network of investors working
PAI Principal Adverse Impacts - PAIs are together to implement its six aspirational
negative, material, or likely to be material principles, often referenced as "the
effects, on sustainability factors that principles"
are caused, compounded by, or directly
linked to, investment decisions and advice UN SDGs United Nations Sustainable Development
performed by the legal entity. Goals - The UN Sustainable Development
Goals are a collection of 17 interlinked
PCAF Partnership of Carbon Accounting global goals designed to be a shared
Financials - PCAF is a global partnership blueprint for peace and prosperity for
of financial institutions that work together people and the planet, now and into the
to develop and implement a harmonised future. The SDGs were agreed in 2015 by
approach to assess and disclose the GHG the UN General Assembly and are to be
emissions associated with their loans and achieved by 2030.
investments
Value Chain – Upstream: Refers to the activities,
SBTi Science Based Targets initiative - The SBTi Upstream and processes, and inputs that occur early
defines the criteria and verifies near term Downstream in the value chain, such as sourcing raw
and long term GHG emissions reduction materials, supplier management, and
targets for corporates. It has developed manufacturing inputs that are necessary for
guidance and sector specific standards to production.
support target setting.
Downstream: Refers to the activities and
SFDR Sustainable Finance Disclosure Regulations processes that occur later in the value
- SFDR is a disclosure framework for chain, such as distribution, marketing,
asset managers and other financial market sales, and customer service, which deliver
participants. It aims to ensure transparency the finished product to the end consumer.
on the degree of sustainability of financial
products for end-investors in the EU.

TNFD Taskforce on Nature-related Financial

Disclosures - The TNFD is developing a risk
management and disclosure framework for
organisations to report and act on evolving
nature related risks, with the ultimate aim of
supporting a shift in global financial flows
away from negative outcomes and toward
positive outcomes for nature.

TPI Transition Pathway Initiative - The

Transition Pathway Initiative is a global,
asset-owner led initiative which assesses
companies' preparedness for the transition
to a low carbon economy.
Unpacking CSRD: A Guide for Business 8
Unpacking CSRD: A Guide for Business 9

1. Executive Summary
The Corporate Sustainability Reporting Directive modernises sustainability
reporting in business making non-financial (NF) Environmental, Social and
Governance (ESG) information as important and regulated as financial reporting
has been for over a century. This change underscores the critical role of NF ESG
data in managing a company’s performance and ensuring long-term success.

Effective from 2024, the CSRD will impact over Given the scale of changes required and the volume
50,000 companies across the EU, including listed of data involved—with a minimum of 161 mandatory
entities, large private companies, and and listed datapoints, in line with EFRAG guidance—
SMEs, greatly expanding the scope from the early preparation is crucial. Businesses should
12,000 companies previously covered under the engage both internal and external stakeholders
Non-Financial Reporting Directive (NFRD). The early on—ranging from senior leadership to key
directive now applies to a broader range of sectors, operational teams—to ensure a seamless transition.
encompassing both private and public companies, A methodical approach, including ample lead
and integrates mandatory and material ESG data time, will help to navigate the complex regulatory
into management reporting through a ‘Sustainability environment that CSRD introduces.
Statement’ with detailed disclosure requirements.
While the transition period and initial years of
One of the fundamental aspects of the CSRD is the reporting under the CSRD may present challenges,
obligation to ensure that financial stakeholders— the directive ultimately brings clarity and
including investors, lenders, and insurers—have consolidation across various reporting standards.
access to reliable, standardised data. This enables It aligns with other reporting requirements and
them to evaluate the risks posed by climate change provides an opportunity for businesses to identify
and other sustainability concerns on investments, strategic advantages through sustainable practices.
lending decisions, and business partnerships. By embedding sustainability into core business
Importantly, the CSRD also mandates the strategies, companies can gain competitive
verification of disclosed data through assurance, advantages, operational efficiencies, and market
initially at a ‘limited assurance’ level, with a differentiation, positioning themselves for long-term
transition towards ‘reasonable assurance’ to ensure resilience and growth.
data quality and avoid greenwashing.
In conclusion, although the journey to full CSRD
Even companies already publishing comprehensive compliance may be demanding, it also presents
sustainability reports will likely find the CSRD an opportunity to lead with purpose, demonstrate
a substantial step up in the quality, scope, and responsible business practices, and contribute
assurance of required data. Nevertheless, many of meaningfully to the wider goals of the EU Green
the processes already in place within businesses Deal and the UN Sustainable Development
can serve as a solid foundation for meeting Goals. Embracing the CSRD is not just about
these new standards and advancing sustainable compliance—it is about turning sustainability into a
practices. strategic asset for the future.
Unpacking CSRD: A Guide for Business 10

Navigation of Toolkit Contents

The toolkit provides comprehensive guidance on the Corporate Sustainability Reporting
Directive (CSRD) and its requirements, featuring both high-level overviews, peer case
studies and detailed practical steps for implementation. Below is an outline of the key
sections:

• Section 2: Demystifying CSRD provides a clear introduction to what the CSRD

entails, including its application, scope, timeline, and its wider context within EU
regulatory frameworks like SFDR and the EU Taxonomy. It also explains how CSRD
aligns with international reporting regimes.

• Section 3: ESRS Standards Playbook explores the European Sustainability

Reporting Standards (ESRS) that underpin CSRD disclosures. It breaks down the
various topics, subtopics, and sustainability matters, alongside guidelines for ensuring
compliance with these standards.

• Section 4: CSRD Implementation delivers a step-by-step guide for companies,

outlining the compliance roadmap, the importance of a Double Materiality
Assessment, and the role of stakeholder engagement in the process. This section
also includes practical tools like gap analysis methods and guidance on preparing
Sustainability Statements.

• Section 5: Impact, Risk and Opportunity Assessment helps businesses understand

how to assess their sustainability-related impacts, risks, and opportunities. This
section is crucial for companies looking to integrate sustainability into their business
strategy, and it provides examples of how to turn risks into opportunities.

• Section 6: Topics and Datapoints for Disclosure offers detailed insight into the data
points required under each ESRS topic. It provides practical examples of data points
from climate change (E1) and workforce (S1) areas to help guide reporting.

• Section 7: Grants and Financial Support outlines supports available to businesses

to aid their transition to more sustainable practices. This section includes a variety
of national and EU programmes aimed at assisting companies with sustainability
initiatives.

• Section 8: Further Resources compiles a list of essential resources, including key

legislation, guidance documents, and business supports that will help companies as
they prepare for and navigate the requirements of the CSRD.

Each section is designed to build a clear understanding of the CSRD and provide the
tools and knowledge needed to achieve compliance, helping companies not only meet
regulatory demands but also thrive in this new era of corporate sustainability reporting.
Unpacking CSRD: A Guide for Business 12

2. Demystifying CSRD
What does this section cover?
This section defines what CSRD is, what it aims to achieve and
what corporations it applies to and when.

2.1 What is CSRD?

On 5th January 2023, the EU CSRD entered into force and replaced the current EU
Non-Financial Reporting Directive (NFRD)1. The Irish Government signed the CSRD into
Irish law on the 5th July 20242. CSRD modernises and strengthens the rules on the ESG
information that companies must report on and will require mandatory assurance of non-
financial (NF) information.

Companies within the scope of CSRD will have to report in accordance with 12 detailed
ESG reporting standards, known as the European Sustainability Reporting Standards (ESRS)
which were published by the European Financial Reporting Advisory Group (EFRAG).

European Sustainability Reporting Standards (ESRS)

Environment
E1 - Climate Change
E2 - Pollution
E3 - Water and marine resources
E4 - Biodiversity and Ecosystems
E5 - Resource Use and
Circular Economy

Cross-cutting Standards
ESRS 1 - General Principles
ESRS 2 - General Disclosures Social
S1 - Own Workforce
S2 - Workers in the Value Chain
S3 - Affected Communities
S4 - Consumers and end-users

Governance
G1 - Business Conduct

1 Corporate Sustainability Reporting Directive - European Commission (europa.eu)

2  For further information on the Irish implementing law Corporate Sustainability Reporting - DETE (enterprise.gov.ie) and
additional resources in Section 8.
Unpacking CSRD: A Guide for Business 13

The Directive requires companies to conduct a Double Materiality Assessment (DMA)

to determine the impacts the company has o the environment and society as well as the
financial risks and opportunities relevant to the company.

Financial Materiality
“Outside-In”
Sustainability Matters/
Topics which could have
material financial effects
on the Company

Planet Double Reporting

& Society Materiality Entity

Impact Materiality
“Inside-Out”
Sustainability Matters/Topics
which the Company can have
a material impact externally
- i.e. on the planet & society

For mandatory and material impacts, the disclosure requirements aligned with specific
data points outlined in the ESRS include the following:

• Governance

• Strategy, Policies, Procedures

• Impact, Risk & Opportunities Management that considers the Short (Current Financial
Year), Medium (5+ Years), and Long-term (10+ Years) time horizons

• Metrics & Targets

An example of an ESRS is E1 – Climate Change. Under E1, CSRD mandates that

companies set Greenhouse Gas (GHG) emission reduction targets that are science-
based and aligned to the Paris Agreement (compatible with limiting global warming to
1.5 degrees Celsius). It also requires Climate Transition Plans and to make the necessary
investments to achieve these targets, with the goal of reaching net zero emissions by
2050.
Unpacking CSRD: A Guide for Business 14

CASE STUDY

Bank of Ireland
Our commitment to sustainability is grounded in our central belief
that supporting our customers, colleagues and society, while
appropriately allocating our capital, will create long-term value for our
shareholders.

Sustainability is a key strategic pillar for us and reporting with

transparency and accuracy is critical to ensuring the Group creates
meaningful progress by highlighting where key actions are needed.
The CSRD represents the next iteration of reporting in Europe,
bringing with it comparability, clarity and the requirement for auditable “Our large corporate customers
sustainability disclosures. The Group is in scope for the CSRD and are grappling with the scale of
will report on 2024 performance, aligned to the ESRS, in February the disclosure requirements,
2025. These disclosures build on the Group’s voluntary sustainability the challenge of identifying the
reporting under the Global Reporting Initiative (GRI) and other right tools to track the data,
frameworks including the UNPRB (United Nations Principles for resourcing up the required
Responsible Banking) and TCFD (Task Force for Climate-Related staffing capability and the
Financial Disclosures). necessary audit trails, which
some businesses are putting
CSRD will also impact our business customers: many of our in place for the first time. SME
customers are (or soon will be) in scope but far more will be impacted businesses, on the other hand,
indirectly as supply chain partners of larger entities. This poses do not have the clarity of the
challenges, in measuring, monitoring, and communicating ESG Directive and must engage
progress. Our large corporate customers are grappling with the scale with their corporate customers
of the disclosure requirements, the challenge of identifying the right to understand the data and the
tools to track the data, resourcing up the required staffing capability level of validation that will be
and the necessary audit trails, which some businesses are putting in needed going forward.”
place for the first time. SME businesses, on the other hand, do not
have the clarity of the Directive and must engage with their corporate – Bank of Ireland
customers to understand the data and the level of validation that will
be needed going forward.

The challenges of CSRD should not be underestimated – gathering

and validating the information across large organisations while
developing auditable data trails at the scale required by the Directive
is a substantial undertaking for any business. Notwithstanding these
difficulties, the Group welcomes the Directive – the disclosures
bring about enhanced accountability which will lead to increased
monitoring of ESG performance and will ultimately drive positive
change across Europe.
Unpacking CSRD: A Guide for Business 15

2.2 Application and Timeline

Companies in scope for FY 2025 are EU entities (including EU subsidiaries of non-EU
parent companies) that meet two or more of the following criteria:

• 250+ employees

• Total balance sheet of €25m+

• Net turnover of €50m+

The CSRD applies to fiscal years starting on or after 1 January 2024, with reporting
starting from 2025 on a phased basis. The timeline for submitting the first CSRD
compliant report is based on the criteria below.

• Companies previously subject to the Non-Financial Reporting Directive (NFRD)

(public interest entities (PIEs) large, listed companies, large banks and large insurance
undertakings with more than 500 employees), as well as large non-EU listed
companies with more than 500 employees: financial year 2024, with first sustainability
statement published in 2025.

• Other large companies, including other large non-EU listed companies: financial year
2025, with first sustainability statement published in 2026.

• Listed SMEs, including non-EU listed SMEs: financial year 2026, with first
sustainability statements published in 2027. However, listed SMEs can opt out of the
reporting requirements for an additional two years.

• Non-EU companies generating over €150 million per year in the EU and that have
in the EU either a branch with a turnover exceeding €40 million or a subsidiary that
is a large company or a listed SME will have to report on the sustainability impacts
at the group level of that non-EU company as from financial year 2028, with first
sustainability statement published in 2029.

The timelines for phasing in, along with the actions companies need to take, are
summarised overleaf.
Unpacking CSRD: A Guide for Business 16

Requirement Who When What Action Required

Large, listed corporates FY 2024 Comply with Prepare to submit

> 500 employees (publication 12 detailed an ESRS-compliant
2025) ESRS reporting report
standards.
Large EU corporates (including EU subsidiaries FY 2025 Conduct a
of non-EU parent companies) who exceed at (publication Phased Double Materiality
least two of the following criteria: 2026) introduction Assessment
Corporate of certain
Sustainability • 250+ employees Gather required
requirements.
Reporting • Total balance of €25m+ information
Directive
(CSRD) • Net turnover of €50m+ Prepare for digital
data tagging 3rd
Listed SMEs: While there is no legal obligation
Party Assurance
for non-listed SMEs, guidance is expected
to be published for them in time. EFRAG has
published a draft of its voluntary reporting
standard for SMEs which are expected to be
finalised in 20253

TOP TIP
Seeking legal clarification is advised to check the requirements and
timelines specific to each corporation and any exclusions that may apply.

2.3 Companies in Scope by Sector and Size

Globally, a minimum of 50,000 companies are expected to be subject to CSRD, either
directly or through their involvement in the value chain of a corporate entity, as illustrated.
This is particularly important for SMEs and others to take into consideration.

A sectoral breakdown of the companies covered by CSRD, including large caps

(companies with a market capitalisation of more than $10billion) and SMEs shows the
manufacturing sector as the most significant impacted, followed by financial services4.

3  EFRAG’s SME-focussed resource pages SMEs | EFRAG

4 Monitoring Capital Flows to Sustainable Investments, April 2024, Annex 2: Annexes to the Platform on Sustainable
Finance intermediate report on monitoring capital flows to sustainable investments (europa.eu)
Unpacking CSRD: A Guide for Business 17

Breakdown of Companies in the Scope of CSRD by Type (Source: EU Monitoring

Capital Flows to Sustainable Investments, April 2024)

Number of
Scope Share of total Entry into Force
companies

Listed EU companies with more than 500 companies (1,604

1,956 4% 2024
from real economy)

Other companies due to national transposition 9,697 20% 2024

Total (existing NFRD) 11,653 24% 2024

Large public interest entities below 500 employees 1,157 2% 2025

Large non-EU (*) undertakings listed in the EU 86 <1% 2025

Large non-listed EU undertakings 35,184 72% 2025

EU listed SMEs 1,059 2% 2028

Total New 37,486 76%

Total CSRD 49,139 100% 2028

Source: Reproduced from J.P. Morgan (2023)

(*) Note: Non-listed foreign entities that generate a net turnover of EUR 150 million in the EU and have a
subsidiary undertaking or a branch on the territory of the EU that generates at least turnover of EUR 40 million.
Entry into force refers to reference year. Reporting for listed SMEs is mandatory from 2028 onwards

SMEs that are not in scope of CSRD but within the value chain of in scope companies
should expect these companies to apply “reasonable effort” to collect sustainability
information. The size, resources and technical readiness of the actor in the value
chain are among the criteria used to establish what constitutes as “reasonable effort”.
Therefore, larger SMEs with experience that have previously reported sustainability
information may be exposed to higher expectations than smaller SMEs that have never
voluntarily reported5.

5  See p31 Commission’s FAQs Frequently asked questions on the implementation of the EU corporate sustainability
reporting rules (europa.eu))
Unpacking CSRD: A Guide for Business 18

CASE STUDY

Idiro Analytics
We are not in scope of CSRD but like many Small and Medium Enterprises
(SMEs) we are in the supply chain of organisations who are in scope.

In June 2023, as part of our commitment to a client, a large financial

institution, we undertook a carbon audit to support their CSRD reporting
obligations. The process, carried out using the not-for-profit CDP’s (Carbon
Disclosure Project) tool, proved to be a challenging task, replete with
complexities and technical jargon that were unfamiliar to us as an SME.

The audit required us to engage with new concepts and metrics that were
outside our usual scope of expertise. This included calculating the carbon
footprint of various aspects of our operations, such as our electricity
consumption and the carbon cost of our cloud compute usage – neither “This lack of detailed
of which were readily at hand for us to access. We had our client’s data made it difficult
understanding with this, a new process for all stakeholders. to accurately assess
our electricity-related
For example, the challenge in calculating our electricity consumption arose emissions, adding a layer
from the fact that we operate in a serviced office where electricity is included of ambiguity to the audit.
in the overall fee. Our landlord could not provide a breakdown of our specific To meet this challenge, we
electricity usage because the building has multiple tenants but only one ascertained typical average
electricity meter. This lack of detailed data made it difficult to accurately electricity consumption
assess our electricity-related emissions, adding a layer of ambiguity to the levels from sources
audit. To meet this challenge, we ascertained typical average electricity including ICT equipment
consumption levels from sources including ICT equipment guides. guides.”

Other challenges included understanding the specific metrics required – Idiro Analytics
for reporting and the methods for accurately calculating emissions from
various sources. For instance, determining the carbon footprint of employee
commutes involved collecting detailed data and applying calculation
methods that were not straightforward.

Overall, the process was time-consuming and stretched over six weeks.
Much of this time was spent seeking information and guidance online, often
hitting roadblocks that required additional research to overcome. Available
support and information from some online resources included limitations in
terms of our specific needs, further compounding the difficulty of the task.

While we support government and EU initiatives to move towards net zero,

our experience highlighted several areas for improvement in the carbon
auditing process for SMEs. Firstly, more comprehensive support and
clearer guidance would significantly ease the burden on small businesses.
Additionally, a simplified reporting framework and more accessible
information could help SMEs better manage their environmental reporting
obligations.
Unpacking CSRD: A Guide for Business 19

2.4 Wider Context – SFDR, EU Taxonomy and CSDDD

CSRD is part of a broader package of legislation under the EU Sustainable Finance
Action Plan, which provides the framework to redirect capital flows towards the green
economy. The Plan centres on three core objectives:

• Redirect capital flows towards a more sustainable economy,

• Integrate sustainability into risk management, and

• Promote transparency and long-term thinking in financial markets.

As illustrated below, these disclosures include the Sustainable Finance Disclosure

Regulation (SFDR)6 which regulates investment related disclosures, the EU Taxonomy7
which defines sustainable market activities and the Corporate Sustainability Reporting
Directive (CSRD) which mandates corporate ESG disclosures in reporting. Together,
CSRD, SFDR and the EU Taxonomy create the data “push and pull” factors between
corporates and investors, driving transparency and enabling the transition towards a
green economy.

EU Sustainable Finance Action Plan Other End Users

(civil society
Corporations customers etc.)

CSRD Disclosure Companies

report on environmental, social
and governance issues using
European Sustainability
Reporting Standards (ESRS).

Have to Reporting
publicly information
report goes to
EU Taxonomy Disclosure
Companies report the % of
their current revenues, OpEx and
CapEx coming from activities
aligned with the EU Taxonomy.

SFDR Disclosure Disclose when selling

sustainable financial products.

Products with environmental or social

characteristics or light green products (Article 8). Financial Market Particpants
(asset managers, insurance
Products with a ‘sustainable investment’ companies, pension funds etc.)
objective or dark green products (Article 9), and Financial Advisors.
aligned with the EU Taxonomy.

Source: European Commission

6 The scope of SFDR broadly applies to all financial market participants and financial advisors based in the products and
all financial market participants, as well as non-EU based investment managers or advisors who market their products to
clients in the EU. It applies to financial products such as UCITS, AIFs and portfolios.
7 The EU taxonomy initially applied to companies that were previously subject to NFRD. CSRD extends the scope of
application of the EU Taxonomy and closely aligns it with the scope of CSRD.
Unpacking CSRD: A Guide for Business 20

With CSRD, the final piece of the EU Sustainable Finance Action Plan slots into place. By
requiring corporates to report on non-financial ESG data, publish Climate Transition Plans
and disclose under the EU Taxonomy (including turnover, CapEx and OpEx), financial
stakeholders can more easily assess climate -related risks and opportunities in their
lending, asset, insurance portfolios. Climate risk assessments are becoming regulated
and will become essential across financial services sector, driving pricing differentials
between companies aligned with the transition and those that are not.

In July 2024 another EU sustainability and ESG-related directive entered into force: The
Corporate Sustainability Due Diligence Directive (CSDDD). This directive aims to reduce
the risk of adverse human rights and environmental impacts arising within global value
chains. It sets out requirements for companies to conduct due diligence across their
own operations, subsidiaries, and upstream and downstream chain of activities. Under
CSDDD, companies in scope will also be required to publish and put into effect a climate
transition plan to ensure the companies’ business model and strategy are aligning with
the Paris Agreement and limiting of global warming to 1.5 degrees Celsius. The directive
will first apply to the largest companies in 2027, with additional companies being brought
into scope over the following two years.

While CSDDD8 focuses on the active management of sustainability risks within company
operations and their supply chains, CSRD mandates the reporting and public disclosure
of these risks.

CASE STUDY

Ornua
“Ornua’s ESG strategy, ‘Common Ground,’ outlines Ornua’s commitment
to safeguard the environment, create better outcomes for people and bring
responsibly produced, quality products to the world. One of the enablers that will
drive the delivery of these commitments is our ESG reporting activity and making
ESG a core part of the business as usual beyond reporting. At Ornua, our ESG
reporting journey has been progressed through key milestones and integration of
reporting frameworks including CDP, WRAP, Origin Green and TCFD, with the next
step now CSRD.”

– Ornua

8 Ireland must transpose the CSDDD into national law by 26 July 2026. The scope of CSDDD provides for a phased
application based on company size and turnover for both, EU and non-EU companies. For more information Corporate
sustainability due diligence - European Commission (europa.eu)
Unpacking CSRD: A Guide for Business 21

2.5 CSRD and International Reporting Regimes

In addition to CSRD, mandatory sustainability and climate disclosure requirements are
being rolled out internationally. Therefore, if the CSRD does not impact a company, the
international IFRS (International Financial Reporting Standard Foundation) S1 Climate
and S2 Sustainability Disclosure Standards published in 20239 and developed by the
International Sustainability Standards Board (ISSB) are likely to do so as they phase in.
While less onerous than CSRD, they will drive accountability on climate change and
broader ESG topics across global markets. The S1 Climate Disclosure Standard takes
over from the Financial Stability Board’s (FSB) Task Force on Climate related Financial
Disclosures (TCFD)10 which is now enforced under the IFRS regime.

There is a high degree of alignment of the ISSB and CSRD disclosure standards to
ensure interoperability. In fact, almost all ISSB disclosures related to climate are included
in the CSRD ESRS11. CSRD has collaborated with other mainstream international
sustainability reporting regimes to ensure interoperability. This will bring consolidation
across a range of reporting standards and requirements. For example, this includes, the
Sustainability Accounting Standards Board (SASB) standards (now part of the IFRS), the
Global Reporting Initiative (GRI) which provides a voluntary ESG reporting framework,
and the TCFD. This consolidation will ultimately save businesses time and result in better
quality and comparable data for regulators, shareholders, and other stakeholders.

Beyond the EU, in the US the Securities and Exchange Commission (SEC) adopted a
new climate rule in March 2024, requiring companies to disclose climate related risks
that are reasonably likely to have a material impact on their business strategy, operations
or financial condition. However, legal challenges have led the SEC to delay the
enforcement of the new rules pending a review in the US Court of Appeals. Additionally,
in 2023 the state of California passed three climate disclosure laws, the Climate
Corporate Data Accountability Act (SB-253), the Greenhouse gases: climate-related
financial risk Act (SB-261) and the Voluntary carbon market disclosures Act (AB-1305).
These laws mandate ESG disclosure for certain US and international companies
conducting specific business activities in California.

International Sustainability and Climate Disclosure Regimes with which CSRD is Interoperable

Mandatory Sustainability
Corporate Sustainability Reporting Directive
Reporting

GRI SASB
Global Reporting Initiative Sustainability Accounting
Sustainability in Standards Board
Financial Reporting
ISSB
IFRS TCFD
The International Financial Task Force on Climate-Related
Reporting Standards Foundation Financial Disclosures

ISSB Purpose Unified Approach to ESG Reporting

Improve Data Consolidate

Key Principles Avoid Greenwash Global Approach
Quality Standards

Source: Davy Horizons Sustainability Consultants | Davy Horizons

9 IFRS - Home
10 Task Force on Climate-Related Financial Disclosures | TCFD) (fsb-tcfd.org)
11 esrs-issb-standards-interoperability-guidance.pdf (ifrs.org)
Unpacking CSRD: A Guide for Business 22

The roadmap ahead for business across CSRD related regulations and disclosure regimes impacting the
EU, US/international and UK is illustrated.

Sustainability Reporting Requirements timeline

EU US/Int UK

SFDR*
Disclosure ISSB
2021 Requirements
Apply
Established

EU Taxonomy
Eligibility Disclosure TCFD Mandatory
Disclosures
2022 (NFRD Companies)

Diversity Targets
CSRD*** Adopted Disclosure

EU Taxonomy
Alignment Disclosure Climate
2023 (NFRD Companies) IFRS S1 &
S2 Issued
Transition Plan
Reporting
ESRS Adopted

CSRD Applies
(NFRD Companies)
2024 SEC Climate
Ruling
Pillar lll Climate Risk

CSRD Applies
(Large Companies) Updated UK
2025 CSRD Disclosures
Corporate
Governance
Code
(NFRD Companies)

CSRD Disclosures

2026+ (Large Companies)

CSDDD

Source: Davy Horizons Sustainability Consultants | Davy Horizons

** Sustainable Finance Disclosure Regulation (SFDR)

** Non-Financial Reporting Directive (NFRD) in EU from 2018
*** Corporate Sustainability Reporting Directive (CSRD)
Unpacking CSRD: A Guide for Business 23

CASE STUDY

Coillte
Coillte is considered a large company with its first CSRD reporting
obligations in 2026. Our initial focus was on various aspects of CSRD’s
cross-cutting reporting standards – particularly in relation to materiality
and sustainability-related governance. The second key preparation
area was ESRS E1 which centres around climate change disclosure.
This standard aims to align with the Paris Agreement’s goal of limiting
global warming to 1.5°C above pre-industrial levels and requires
organisations to reveal both positive and negative impacts related to “In preparation for CSRD, in
climate change. It is composed of three sub-topics: climate change 2021, Coillte signed up to the
adaptation, climate change mitigation and energy. Its disclosure Task Force on Climate-Related
requirements have over 200 data points which are both narrative and Financial Disclosures (TCFD)
numerical. which is arranged around 4
thematic areas: governance,
In preparation for CSRD, in 2021, Coillte signed up to the Task Force strategy, risk management
on Climate-Related Financial Disclosures (TCFD) which is arranged and targets & metrics. As all
around 4 thematic areas: governance, strategy, risk management TCFD disclosures are covered
and targets & metrics. As all TCFD disclosures are covered in ESRS in ESRS E1, the framework
E1, the framework provided us with the initial guidelines and a provided us with the initial
reporting structure. It allowed us to develop a better understanding guidelines and a reporting
of our climate related financial risks and opportunities and to identify structure. It allowed us to
potential actions which included both adaptation to the changing develop a better understanding
environment but also ways to reduce our carbon footprint. of our climate related financial
risks and opportunities and to
One of the most important pieces of work completed was GHG
identify potential actions which
modelling of Coillte’s estate. During 2022, Coillte worked with a
included both adaptation to
number of leading experts to determine the current GHG profile of
the changing environment but
Coillte’s forest estate and also to identify and assess the climate
also ways to reduce our carbon
change mitigation potential of silvicultural management options.
footprint.”
Consequently, a number of actions to increase carbon removals in the
estate by circa 10m tonnes of CO2 by 2050 were incorporated into – Coillte
Coillte’s forestry strategic vision launched in April 2022.

In addition, a baseline assessment of Coillte’s business GHG emissions

across the Scope 1 and 2 categories was completed in 2022 and an
assessment of Scope 3 commenced in 2023. Key GHG reduction
pathways were identified and targets for Scope 1 and Scope 2 emissions
were agreed. We are currently finalising our Scope 3 emissions and hope
to verify Coillte’s GHG reduction targets through the Science Based
Targets initiative (SBTi). Last year we also engaged in a pilot test of the
GHG Protocol Land Sector and Removals Guidance (Forests, Land and
Agriculture - Science Based Targets Initiative)12. The pilot gave Coillte
the opportunity to test the draft guidance and to provide suggestions for
improvement of the final version.

12 https://sciencebasedtargets.org/sectors/forest-land-and-agriculture
Unpacking CSRD: A Guide for Business 24

In 2023, Coillte conducted a comprehensive climate scenario

analysis assessment which deepened our insights into potential
climate impacts on Coillte’s business and operations and assessed
the Group’s strategy resilience under various climate risks and
opportunities. This analysis was included in our annual report for 2023
and can be viewed at www.coillte.ie.
Unpacking CSRD: A Guide for Business 25
Unpacking CSRD: A Guide for Business 26

3. ESRS Standards Playbook

What does this section cover?
This section outlines the 12 ESRS standards and fundamental
concepts they require, including sustainability due diligence
and Double Materiality (DM). The 12 ESRS standards, along
with the EFRAG Double Materiality guidance, provide the
playbook to be used to conduct the DM assessment (DMA) and
CSRD gap analyses to support companies prepare for CSRD
compliant reporting. Over time, sector specific standards will
offer additional guidance for several high-impact sectors. These
standards, currently being developed by EFRAG, were initially
expected to be released and adopted by mid-2024. However,
the EU has recently delayed their adoption to 30th June 2026,
with implementation expected to take place two years after
adoption for the sectors.

3.1 ESRS Standards

The 12 ESRS provide the playbook used to conduct the DMA and CSRD gap analysis to
support the reporting entity prepare for CSRD compliant reporting.

2 Cross-Cutting Standards

ESRS 1
General Requirements

ESRS 2
General Disclosures - Mandatory

Topical Standards - ESG - Mandatory Subject to Materiality

Environment Social Governance

ESRS E1 ESRS S1 ESRS G1

Climate Change Own Workforce Business Conduct

ESRS E2 ESRS S2
Pollution Workers in the Value Chain

ESRS E3 ESRS S3
Water & Marine Resources Affected Communities

ESRS E4 ESRS S4
Biodiversity & Ecosystems Consumer & End-Users

ESRS E5
Resource Use & Circular Economy

Source: COMMISSION DELEGATED REGULATION (EU) 2023/2772 of 31 July 2023 supplementing Directive
2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards -
CL2023R2772EN0000020.0001_cp 1..1 (europa.eu)
Unpacking CSRD: A Guide for Business 27

The core concepts underlying the ESRS under CSRD are sustainability due diligence
and DM, both of which are required as the foundation for sustainability disclosures under
ESRS 1 General Requirements.

Sustainability due diligence requires companies to identify, assess, prevent, mitigate,

and remediate actual and potential adverse impacts arising from its operations, products
or services through its own activities, its business relationships (direct and indirect) and
across the value chain.

Double Materiality: CSRD requires a DM approach requiring disclosure on how the

company’s activities affect or depend on the environment and people, as well as the
company’s financial performance. This should consider short (current Financial Year),
medium (>5 years) and long-term (>10 years) time horizons. The EFRAG Double
Materiality Guidance (June 2024)13 provides supporting context for ESRS 1 on the
method required for the DM Assessment and scoring results to prioritise for action. The
Double Materiality approach is further outlined in Section 4.2.

Details on the two cross-cutting standards ESRS 1 (“General Requirements”) and ESRS
2 (“General Disclosures”) are outlined below.

ESRS 1 (“General Requirements”) establishes the general principles to be applied when reporting
in accordance with ESRS but does not itself set specific disclosure requirements. It includes 10
objectives that need to be addressed. 3 of those are exemplary and are outlined as:

• Double Materiality as the basis for sustainability disclosures and materiality of information.

• Time horizons (e.g. reporting period; linking past, present and future data; tracking and reporting
progress against the base year).

• Linkages with other parts of corporate reporting and connected information (e.g. connectivity
with financial statements).

ESRS 2 (“General Disclosures”) specifies essential information that must be disclosed irrespective
of which sustainability matter is being considered. ESRS 2 is mandatory for all companies under the
CSRD scope and is tied to legal compliance obligations. ESRS 2 covers four main reporting areas:

1. Governance (GOV): Focuses on governance processes and controls used to monitor and
manage impacts, risks, and opportunities.

2. Strategy (SBM): Explores how a company’s business strategy interacts with its material impacts,
risks, and opportunities, including strategies for addressing them.

3. Impact, Risk, and Opportunity Management (IRO): Details the process of identifying, assessing,
and managing impacts, risks, and opportunities through policies and actions.

4. Metrics and Targets (MT): Tracks performance metrics and progress toward goals and targets,
providing a basis for improvement.

13 EFRAG Double Materiality Guidance 2024

Unpacking CSRD: A Guide for Business 28

Disclosure requirements under the remaining ESRS topics that are material to the
company are mandatory to report on. If a company concludes that a disclosure
requirement that is specified in ESRS 2 is not material and therefore does not report in
accordance with that standard, it must provide a detailed explanation of the conclusions
of its materiality assessment regarding that specific topic.

As illustrated below, ESRS 2 General Disclosures defines mandatory disclosures and

datapoints irrespective of materiality and to align with EU law.

Mandatory Information to be Disclosed

The following disclosures/datapoints are to be disclosed and do not
follow the materiality assessment:
A. ESRS 2 – General Disclosures
B. EU Legislation Datapoints (SFDR, EY Benchmarks, Pillar lll,
EU Climate Law). These are in ESRS 2 and topical standards –
refer to Appendix D of ESRS 2 for a full list.
C. E1 – Climate Change
D. S1 – Own Workforce disclosure requirements (DRs) 1 to 9 for
undertakings with 250 employees or more.

Disclosures Subject to the Materiality Assessment

To identify the material impacts, risks and opportunities for the
undertaking within the short-, medium- and long-term.

At Topical Standards

Material Not Material

To disclose the information (including, Brief explanation
policies, actions and targets) as to why not

At Disclosure Requirement and/or Datapoint (Metrics)

Not Material
Material
The undertaking may omit the
To disclose
Disclosure Requirement/datapoint –
the information
Brief explanation as to why not

Content Index / List of all Disclosure Requirements Reported

Source: Based on EFRAG ESRS Overview, November 2022

Other disclosures and datapoints in the ESRS topical standards cover ESG specific
requirements for disclosures on material Impacts, Risks, and Opportunities (IROs) over
the short, medium and long term. These are subject to a DMA.
Unpacking CSRD: A Guide for Business 29

3.2 Topics, Sub-topics and Sustainability Matters

Each topical ESRS under the Environment (ESRS E1-E5), Social (ESRS S1-S4) and
Governance (G1) sections covers “topics” and “sub-topics” for all ESG “sustainability
matters” as below. For example, a sub-topic under S1 - ‘Own workforce’, is ‘Working
conditions’ with sub-subtopics ‘Working time’, ‘Adequate wages’, etc. The specific topics
and sub-topics for the ESRS are detailed further in Section 6. Below is an overview of the
general “sustainability matters” covered by the 10 topical ESRS.

Sustainability Matters Under the ESRS Standards Across ESG Include:

Climate Change Mitigation and Adaptation Working Conditions, Pay and Incentives

Biodiversity and Ecosystem Services Diversity, Equality and Inclusion

Transition to the Circular Economy Wellbeing

Sustainable Products Health and Safety

Human Rights and Modern Slavery Engagement

Responsible Sourcing and Procurement Training

in Value Chains

Source: eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=PI_COM:C(2023)5303

3.3 Value Chain

A value chain focus is required where disclosure of sustainability information from
upstream and downstream activities in the value chain aims to promote sustainable
procurement and decarbonisation, potentially favouring those suppliers who provide
such sustainability information. A value chain encompasses the activities, resources,
and relationships the company uses and relies on to create its products or services
from conception/material sourcing, production, delivery, consumption and end-of-life/
disposal/recycling processes. The value chain includes upstream actors (e.g. suppliers)
and downstream actors (e.g. distributors, customers) from the company.

3.4 Assurance
Assurance and verification are mandatory requirements for CSRD disclosures to ensure
data is credible, reliable and to avoid greenwashing. Initially this will involve a “limited”
assurance level, audited by independent and competent assurance service providers.
In time, this will transition to the more rigorous level of “reasonable” assurance, which is
what is currently required for financial reports. “Reasonable” assurance will require the
use of sustainability assurance standards and practitioners who meet these competency
requirements. The definitions below illustrate the difference for limited and reasonable
assurance.
Unpacking CSRD: A Guide for Business 30

Difference Between “Limited” and “Reasonable” Assurance

Engagements for Auditing

Reasonable assurance engagement — An assurance engagement in which the practitioner needs

to reduce the assurance engagement risk (the risk that an inappropriate conclusion is expressed
when the information on the subject matter is materially misstated) to an acceptably low level. Such
risk is never reduced to zero and therefore, can never be absolute assurance.

Limited assurance engagement — An assurance engagement in which the practitioner collects

less evidence than for a reasonable assurance engagement but sufficient to inform the practitioner’s
conclusion. The practitioner achieves this ordinarily by performing different or fewer tests than those
required for reasonable assurance or using smaller sample sizes for the tests performed.

In traditional auditing, assurance is well defined in assurance engagement standards

such as ISAE 3000 International Standard on Assurance Engagements ISAE3000
Revised, Assurance Engagements Other Than Audits or Reviews of Historical Financial
Information.14 The assurance practitioner is required to comply with the following
fundamental principles of ethics: 1. Integrity 2. Objectivity, including independence 3.
Professional competence and due care 4. Confidentiality 5. Professional behaviour.

As assurance of sustainability disclosure and data continues to develop, standards

are emerging. These are key to supporting corporates ensure assurance is done to the
correct levels to meet auditor requirements. The following best practice standards and
guidance are available and should be used for GHG data assurance and verification:

• ISO 14064-1:2018 Greenhouse gases — Part 1: Specification with guidance at the

organisation level for quantification and reporting of greenhouse gas emissions and
removals.

• ISO14064-3:2019: Specifications with Guidance for the Validation and Verification of

Greenhouse Gas Statements.

• ISO 14065:2020: General principles and requirements for bodies validating and
verifying environmental information, Annex F: Additional requirements applicable to
greenhouse gas validation, verification and AUP (agreed upon procedures).

• ISAE 3410: Assurance Engagements on Greenhouse Gas Statements.

More broadly, the International Auditing and Assurance Standards Board has developed
a global sustainability assurance standard in draft due to complete in 2024. The
proposed International Standard on Sustainability Assurance (ISSA) 5000, General
Requirements for Sustainability Assurance Engagements, will serve as a comprehensive
standard suitable for any sustainability assurance engagements. It will apply to
sustainability information reported across any sustainability topic and prepared under
multiple frameworks, including CSRD and IFRS S1 and S2. It can be used by both
accounting and non-accounting professionals.

14 ISAE 3000 International Standard on Assurance Engagements ISAE3000 Revised, Assurance Engagements Other Than
Audits or Reviews of Historical Financial Information.
Unpacking CSRD: A Guide for Business 31

Assurance practitioners should produce a statement outlining the assurance conducted

that meets current best practice standards and shows their alignment to competency
standards. There is a cost for getting assurance done which should be considered
in budget planning by the business. Costs vary depending on the type of assurance
engagement and number of data sets being assured. To prepare and budget for
assurance, it is essential to meet with your financial auditor and agree clear expectations
as you prepare for CSRD compliance reporting.

Role of the CEO/Board/Audit Committee in Assurance

The CEO and Board have central roles in the CSRD assurance process, ensuring
oversight of sustainability disclosures and their alignment with corporate governance.
They must ensure independent assurance providers verify the accuracy of data, oversee
the transition from limited to reasonable assurance, and ensure compliance with
CSRD standards. The Board, particularly through the Audit Committee, is responsible
for embedding sustainability into governance, aligning with both ESRS and CSRD
requirements.
Unpacking CSRD: A Guide for Business 32

CASE STUDY

Energia Group
As a company committed to powering the energy transition across the
island of Ireland, sustainability is central to our business strategy and
approach. Our preparation for CSRD has built on foundations we had in
place to support our commitment to sustainability and that have helped
us to embed these practices across the Group. In the first instance,
aligning our business activities to the UN Sustainable Development Goals
and participating in a number of voluntary disclosures, highlighted the
“A key workstream and one
benefits of good governance and the importance of data. These aspects
of the first to be established
remain central to our approach to CSRD.
in our CSRD Programme was
Recognising that the implementation of CSRD reporting is a large and the data project. Data drives
complex programme of work, involving all parts of the business, we strategic decisions and insights
have evolved our ESG Governance structure to incorporate our CSRD across our business every
Programme. As part of this structure, our ESG Steering Group, which day and the data required for
is chaired by the Group CFO and incudes senior representatives from ESG reporting is no different.
across the Group, provides direction and oversight for the Group’s CSRD The impact of CSRD and the
programme. This provides an awareness of all CSRD-related activity ESRS framework specifically
across the Group, including at Board level, and ensures the activities are has been to formalise and
effective and consistent with the broader Group strategy. significantly increase the data
requirement for reporting.
Supported by a small number of Working Groups, our CSRD Programme Comprising data inputs from
has 11 distinct workstreams that involve subject matter experts in the across the Group, a “data
different businesses across the Group. Each workstream has a number of lake” is being established to
set objectives and workstream leads report regularly to the ESG Steering house all relevant data for
Group on progress. This approach, particularly in a large organisation with CSRD reporting. This approach
a set deadline for compliance, requires structure but through participation, ensures consistency with
also helps to embed sustainability, identify opportunities and facilitate other Group reporting and is
transformational change. intended to facilitate the audit
requirement for CSRD.”
A key workstream and one of the first to be established in our CSRD
Programme was the data project. Data drives strategic decisions and – Energia Group
insights across our business every day and the data required for ESG
reporting is no different. The impact of CSRD and the ESRS framework
specifically has been to formalise and significantly increase the data
requirement for reporting. Comprising data inputs from across the Group,
a “data lake” is being established to house all relevant data for CSRD
reporting. This approach ensures consistency with other Group reporting
and is intended to facilitate the audit requirement for CSRD.
Unpacking CSRD: A Guide for Business 33

To date, our focus has been on developing a robust internal data

collection and verification framework. This has involved a detailed
mapping of the ESRS requirements across the ESG standards, to the
existing data across the Group. This process has also identified possible
gaps and assessed the quality of existing data, as well as technical
considerations for consolidating data from different businesses and
platforms within the Group.

There is clearly no “one size fits all” approach to CSRD reporting but a
formal governance structure has been a key enabler of our progress on
CSRD to date, as well as wider ESG initiatives. The importance of data
to CSRD is undeniable and should be understood early in the process,
particularly given the formal audit requirements for reporting. Ultimately
CSRD is a reporting requirement but, through our approach, we have also
found it to be an opportunity for positive engagement and change across
the Group, benefiting our colleagues, the business and our customers.
Unpacking CSRD: A Guide for Business 34

3.5 Digital Data Tagging

What is Digital Data Tagging?

Digital data tagging involves labelling data within digital documents using specific codes to make the
information machine-readable and easily accessible. This is done through the Extensible Business
Reporting Language (XBRL), a standardised language for exchanging business information. By applying
XBRL tagging to sustainability reports, organisations can enhance data quality, ensure transparency,
and facilitate the comparability of information across industries. This digitisation supports detailed data
collection and helps prevent greenwashing by ensuring that reports are verifiable and reliable.

Current Use in Financial Reporting in Ireland

XBRL is already widely used in financial reporting in Ireland. Since 2014, Irish Revenue Commissioners
have mandated the submission of financial statements in iXBRL format as part of corporate tax returns.
This requirement applies to all companies submitting Corporation Tax returns, allowing for automated
processing of business information, significantly reducing manual data entry and improving data accuracy
and efficiency. The use of iXBRL ensures that both humans and machines can read the reports, which
streamlines the reporting process and enhances data quality.

Use in CSRD Reporting

Organisations will soon be required to expand their use of digital data tagging, extending beyond financial
reporting. This expansion aims to facilitate digital submissions and enhance access to disclosed data
points in organisations’ sustainability disclosures and reports. Under the European Single Electronic
Format (ESEF), digitisation will be implemented using XBRL, making reports machine-readable and easily
accessible.

To prepare for this transition, organisations must take essential and proactive steps including:

• Upgrading IT systems

• Training staff on new standards

• Enhancing data management practices

• Staying informed about monitoring and implementing upcoming XBRL guidance and regulatory changes

Through these measures, organisations can ensure compliance with the CSRD reporting mechanisms,
thereby aligning with broader regulatory expectations, and contributing to sustainable business practices.
Unpacking CSRD: A Guide for Business 35

3.6 Sectoral Standards

Beyond the 12 sector-agnostic ESRS, EFRAG is currently developing sets of sector-
specific ESRS for 8 different sectors. This process consists of several draft stages with
research, drafting, validating and approval exercises with adoption of the standards
planned for June 30th 2026.

List of sector guidance in development at the time of writing this guide (Source: Sector-specific ESRS |
EFRAG)

Sector Stage

Oil and Gas Approval of Exposure Draft

Coal, Quarries and Mining Approval of Exposure Draft

Road Transport Validating

Textiles, Accessories, Footwear and Jewellery Validating

Agriculture, Farming and Fisheries Early Draft - Research

Motor Vehicles Early Draft - Research

Energy Production and Utilities Early Draft – Research

Food and Beverages Early Draft - Research

Financial Institutions Early Draft - Research

Unpacking CSRD: A Guide for Business 37

4. CSRD Implementation
What does this section cover?
This sets out a step-by-step guide for implementing CSRD
requirements with templates to use and additional case
examples to illustrate.

4.1 Compliance Roadmap

Aim: To comply with CSRD, reporting entities in scope must publish a CSRD compliant
set of disclosures in a Sustainability Statement, which should be part of the annual
integrated report. This must be aligned with the ESRS standards for all mandatory
disclosures and datapoints, plus those identified in the DMA.

Roadmap: To prepare for the first CSRD compliant report, the following steps should be
implemented:

Double Materiality Assessment

(DMA) – Conduct a DMA, which
is mandatory under CSRD.

Stakeholder Engagement
– As part of the DMA, conduct
stakeholder engagement across all
Gap Analysis on Disclosure relevant groups.
requirements – Conduct a gap
analysis against the 12 ESRS
standards for mandatory and
material issues. Identify
recommended actions to fill the Data Gathering – Collect the
gaps. required data for both mandatory
and materiality-based disclosure
requirements.

Digital Data Tagging

Preparation – Prepare for digital Third Party Assurance
data tagging (XBRL). Preparation – Ensure readiness for
third party assurance of data,
aligning to competencies outlined in
the ESRS and relevant standards.
Unpacking CSRD: A Guide for Business 38

The DMA must be aligned to the method outlined in CSRD, as specified in ESRS 1 and
the supplementary guidance in EFRAG IG 1: Materiality Assessment15.

If the company has completed a DMA or Materiality Assessment already this should
be used as one input. Stakeholder engagement should be aligned to the DM approach
conducted across all required channels - customers, employees, suppliers, core
shareholders, core lenders, and internal subject matter experts.

The DMA should review the reporting entities key sustainability impacts, risks and
opportunities (IRO) considering both impact and financial materiality.

The scope of the DMA should incorporate all the activities of the reporting entity across
its operations and value chain, including Group and its subsidiary business unit activities.

Feedback from stakeholders should be scored, weighted, and presented in a priorities

list and DM matrix or similar, (see section 4.5) to facilitate communication and ensure
compliance for CSRD reporting.

4.2 Double Materiality Assessment

The CSRD aligned DMA has two dimensions, impact materiality and financial materiality
as defined below:

• Impact materiality - Identifies the material impacts, risks, and opportunities to be

reported. A sustainability matter is a material impact when it pertains to the entity’s
actual or potential, positive or negative impacts on people or the environment over the
short, medium or long-term. This covers own operations, products and services, and
operations in the value chain. Materiality is based on scale (low, medium, high), scope
(limited, concentrated, global) and likelihood of the impacts. For negative impacts,
it is also based on the irremediable character of the impact (from easy to remedy, to
irreversible). Companies must assess their dependence on availability of natural or
social resources at appropriate prices and quality, and how this affects the business
thinking of scarcity of supply (labour and resources).

• Financial materiality – Sustainability matters are material from a financial perspective

for reporting if they trigger, or may trigger, material financial effects on the undertaking.
This is the case when it generates risks or opportunities that have a material influence
on cash flows, development, performance, position, cost of capital and access
to finance in the short, medium or long term. Risks and opportunities may impact
assets, liabilities, types of capital, or other factors of value creation. An impact may be
financially material for reporting from inception, or become financially material when
it becomes investor, lender or creditor relevant. Dependencies on natural and social
resources can also present financial risks or opportunities. For example, if a business
relies on certain natural resources or social factors, any changes in the availability,
cost, quality, or terms of these resources can impact the business financially. Financial
materiality is judged by considering both the likelihood of these impacts happening
and their potential financial consequences.

15 EFRAG IG 1: Materiality Assessment Implementation Guidance Download (efrag.org)

Unpacking CSRD: A Guide for Business 39

Financial Environmental &

Materialty Social Materiality

To the extent necessary for an

understanding of the company’s ...and impact of its activities
development, performance and position...

climate change company impact

impact on on climate
company company impact
on climate can be
financially material

COMPANY CLIMATE COMPANY CLIMATE

Primary Audience: Primary Audience: Consumers,

Investors Civil Society, Employees, Investors
Unpacking CSRD: A Guide for Business 40

The steps in the DMA and ranking used are outlined below.

Steps in Double Materiality Assessment (some conducted in parallel) Impact & Financial
Material Ranking
Actual and potential areas of Impacts, Risks and Opportunities (IROs)
are determined by: Very High
5
Impact
• Desktop review of regulatory requirements, best practice, peer
Determine performance, company ESG policies, procedures, data, collection 4 High Impact
1
impacts methods, tools and previous Materiality Assessment, science-
Moderate
based research, plus stakeholder engagement. 3
Impact
• 12 x ESRS standards, list of sustainability matters, topics and
2 Low Impact
subtopics.

Agree and Very Low

• Internal Subject Matter Experts and governance committees 1
engage key Impact
stakeholders • Users of reporting - own workforce colleagues, customers,
2
by interviews, suppliers, core shareholders and lenders.
workshops and
• Affected stakeholders – local communities.
surveys

Informed by:

• Workshops and surveys with the Subject Matter Experts, Chief

Sustainability Officer or Head of Sustainability (if the business has
one), Sustainability Executive Committee and Board.

• Surveys for stakeholders across agreed stakeholder groups

Rank importance (Subject Matter Expert colleagues, customers, suppliers) and
of impact to interviews with core shareholders and lenders.
3
business, society
• A long list of IROs is identified. Impacts are assessed based on
& environment
severity (scale, scope, ability to remediate) and likelihood to occur.

• An Impact scale of Low (1) to High (5) as illustrated can be used

to rank priorities based on severity for actual negative impacts
and likelihood for potential negative impacts. Severity is based on
the scale, scope and irremediable character of negative impacts
and the scale and scope of positive impacts.

• Impacts determine the level of importance identified as material

for reporting in line with the ESRS ESG standards for the related
Determine topics and subtopics. The simple impact scale Low (1) – High (5)
4 impacts material as illustrated can be used.
for reporting • This identifies a short list of impacts material for reporting. This
should be sense checked with Subject Matter Experts and
governance committees.

• For material E&S impacts, the level of financial impact on

business performance, profitability, growth, and reputation should
Assess the be determined.
5 financial
materiality • Workshops and surveys with internal Subject Matter Experts,
financial functions and the Sustainability Executive Committee
should inform this and rank importance of impacts.

Determine
financial impacts Based on likelihood and scale of severity of the financial impact,
6
material for financial impacts material for reporting should be determined in line.
reporting

The DM Matrix should be refined based on final Subject Matter Experts

Validate and
7 and governance committee feedback, issues grouped, and a final matrix
refine
presented to the board for sign off.
Unpacking CSRD: A Guide for Business 41

CASE STUDY

Fyffes
Fyffes was a relative newcomer to sustainability reporting, when
in 2021 we published our first Sustainability Report because, as
a privately owned company, we were not required to report under
previous frameworks. In line with best practice, in 2018 and 2019
Fyffes conducted a materiality assessment, working with an external
consultant. This resulted in a Materiality Matrix, which formed the
basis of our four sustainability pillars (Stewardship for the Planet,
Healthy Food for Healthy Lives, Enriching People’s Lives and
Responsible Business Conduct) and thirteen sustainability targets,
aligned to nine UNSDGs.

For our first Sustainability Report, we adhered to the GRI Methodology,

which gave us a good grounding in producing content that could be
evaluated by external stakeholders with clear timelines for our Targets, “Since the end of 2023,
which need to be reached by 2025 and 2030. In 2023, we published Fyffes has been collaborating
our second Sustainability Report and gave an update on progress with Freshfel, the Brussels-
against those targets. based fresh produce trade
association, along with
Since the end of 2023, Fyffes has been collaborating with Freshfel, the several other companies in
Brussels-based fresh produce trade association, along with several the fresh produce sector to
other companies in the fresh produce sector to develop a DMA. develop a Double Materiality
Working with an external consultant, the DMA tool will allow the fresh Assessment.”
produce sector to share the costs and knowledge associated with
ESG reporting while increasing the rigour of the individual materiality – Fyffes
assessment work done internally by providing a common framework.
The DMA process includes several external stakeholder interviews
along the entire value chain and is an inclusive and comprehensive
framework.

As a result of Fyffes first Materiality Matrix, human rights, decent

work and living wages were identified as Fyffes foremost material
issues - both from the Company and stakeholders’ perspectives. As
a result, Fyffes began on a journey of human rights due diligence,
long before the CSDDD. Our focus on human rights due diligence has
meant that we have four years of experience conducting human rights
impact assessments, working with independent experts and we better
understand our material risks in this area.

Our next Sustainability Report will be published in 2025 and will

include our next set of targets. These will include existing targets that
are mapped to a 2030 deadline as well as new targets, which will
emerge from the DMA process.
Unpacking CSRD: A Guide for Business 42

In 2026 we will publish our first report under the CSRD requirements. “As a result of Fyffes first
Although getting ready for CSRD requires significant effort and Materiality Matrix, human
involvement of the whole company, it is nonetheless a highly rights, decent work and living
valuable exercise, in helping companies prioritise on those risks and wages were identified as Fyffes
opportunities, including climate change resilience, human rights foremost material issues -
and strong governance that ultimately help companies achieve their both from the Company and
strategy and vision. We would highly recommend companies to stakeholders’ perspectives.
collaborate within their sector, where possible, to share the costs and As a result, Fyffes began on
expertise associated with CSRD. a journey of human rights
due diligence, long before the
Corporate Sustainability Due
Diligence Directive. Our focus
on human rights due diligence
has meant that we have four
years of experience conducting
human rights impact
assessments, working with
independent experts and we
better understand our material
risks in this area.”

–Fyffes
Unpacking CSRD: A Guide for Business 43

4.3 Stakeholder Engagement

Stakeholder engagement aims to seek input and feedback to
understand concerns and identify evidence of actual and potential
impacts of the company on people and the environment. According
to the ESRS, stakeholders are defined as those who can affect, or be
affected, by the company’s decisions and actions. Stakeholders can
be categorised into the following key groups:
“ Sisk’s approach to internal
• Affected stakeholders: Individuals or groups whose interests are, stakeholder management
or could be, positively or negatively affected by the company’s centred on developing a shared
activities and its direct or indirect value chain relationships. This understanding and thus a
includes employees, customers (B2B and B2C), suppliers, and commitment to ownership
local communities. through informal discussion
and more formal workshop
• Users of Sustainability Statements: Primarily those who rely on
and programme along with
financial and non-financial reporting, such as investors, lenders,
direct engagement through the
creditors, insurers, asset managers, business partners, regulators,
double materiality process.”
rating agencies, suppliers, NGOs, trade unions, industry groups,
and civil society.
– Sisk
• Silent stakeholders: Entities such as nature or ecosystems that
are indirectly impacted by the company’s activities but cannot
represent themselves.

Taking these stakeholders into account, the DMA for impact materiality
and financial materiality should identify and analyse material Impacts,
Risks and Opportunities (IROs) and their interconnection.
Unpacking CSRD: A Guide for Business 44

Stakeholder engagement plan

A stakeholder engagement plan should be developed and tailored to the needs of

each stakeholder group. Engagement can be conducted through one-to-one meetings,
webinars, workshops and or surveys where stakeholders are asked to rank the material
topics identified. These topics are rated on a scale of 1 (very low impact) to 5 (very high
impact), considering both impact and financial materiality.

TOP TIP:
The DMA for CSRD is about the appropriate range of stakeholders who can
practically inform materiality across ESG and finance, plus make decisions
on ESG priorities and associated disclosures. One of the most important
groups in this process is the business Subject Matter Experts, who are
decision-making leads across key business functions including:

• Business leads across sustainability, governance, HR, finance,

risk, audit, data.

• Governance committees for sustainability, risk, investment

decision-making.

• The Board.

These Subject Matter Experts are best positioned to determine materiality

thresholds for what should be disclosed once experts do the initial analysis
based on regulatory requirements, science-based research, best practice
and peers. Sustainability Committees, the CEO, CFO, and the Board play an
essential role in the DMA by making the final decisions on prioritising ESG
actions, addressing gaps identified that CSRD requires and determining which
topics are material for disclosure in reporting.
Unpacking CSRD: A Guide for Business 45

CASE STUDY

An Post
Our stakeholders are varied, and the organisation recognises that
their views about our future role in society and the economy are key.
We have been engaging proactively with partners and stakeholders
for a number of years on the topic of sustainability to build a clear
understanding of complex challenges and risks to the business by
understanding their needs, challenges, and concerns. By gathering
this input, and appropriately considering their insights and feedback,
Our sustainability strategy and approach has been informed, shaped
and refined over time.

For transparency and credibility, we have included details of “We therefore tailored our
stakeholders we have engaged with, the means by which we have engagement approach, as
done so, and the topics discussed, in our annual Sustainability Report part of the DMA, to ensure
since 2020. Nevertheless, engagement with stakeholders as part of that we continued to receive
the DMA for CSRD presented a challenge for us. meaningful insights from our
different stakeholder groups.
Complex language and the lack of a clear process to follow in the For example, we used existing
ESRS framework can result in losing sight of the overall objective of channels of engagement
the engagement: to gather feedback and insights on sustainability for citizens to run simple
issues and incorporate it into company strategy and operational surveys ranking sustainability
practices. A generic 30-minute all-encompassing online survey or topics, thereby maximising
face-to-face interview, full of technical sustainability jargon, would response rates. Not only was
not achieve this. Overly complex surveys or interviews can deter this approach highly relevant,
stakeholder participation as well as result in bias, as only those but it was well-documented,
with inherent knowledge tend to respond. We therefore tailored meeting the CSRD assurance
our engagement approach, as part of the DMA, to ensure that we requirements.”
continued to receive meaningful insights from our different stakeholder
groups. For example, we used existing channels of engagement for – An Post
citizens to run simple surveys ranking sustainability topics, thereby
maximising response rates. Not only was this approach highly
relevant, but it was well-documented, meeting the CSRD assurance
requirements.

We will continue to engage meaningfully with our stakeholder groups

on sustainability topics. Listening to, engaging with and responding to
stakeholders is fundamental to An Post being a responsible business
and in delivering on our ambition to create everyday opportunities to
make sustainable living commonplace for everyone in Ireland.
Unpacking CSRD: A Guide for Business 46

4.4 CSRD Gap Analysis

A CSRD Gap Analysis is used to evaluate companies’ current reporting practices in
relation to the requirements outlined in CSRD and the 12 ESRS. It helps companies to
evaluate their status of CSRD implementation, identify where their current reporting falls
short and pinpoint areas that need improvement.

A CSRD and ESRS gap analysis is conducted by:

• A comprehensive expert desktop review: This involves a thorough review of

the company’s existing sustainability strategy (if available), along with its policies,
procedures, KPI metrics, reporting and disclosures against the 12 ESRS Standards
and their underlying disclosure requirements.

• Stakeholder engagement interviews: Key subject matter experts within the

business are interviewed to ensure that the review was complete. Gaps in reporting
against the ESRS disclosure requirements should be identified and prioritised, helping
to inform the company’s Sustainability Strategy and Action Plan.

The CSRD gap analysis assesses preparedness to meet the requirements for material
issues resulting from the DMA. It should include the following criteria and 12 ESRS
standards requirements:

Gap analysis aligned with 12 ESRS Standards

1. Datapoints – review existing data across all mandatory datapoints as defined in ESRS 2 (General
Disclosures) and any additional datapoints identified through the DMA. These encompass
governance, strategy, policies, processes, targets, actions and metrics related to ESG issues.

Key areas of focus:

» Governance - processes, controls and procedures used to monitor and manage risks,
impacts and opportunities.

» Strategy – how the undertaking’s strategy and business model interact with its material
impacts, risks and opportunities and plans to address them.

» Impact, risk and opportunity management – processes to identify, assess and manage
these through policies, plans, procedures and actions.

» Metrics and targets – how performance and process is measured against targets set, KPIs etc.

» Data collection - current approach to sustainability related data collection to inform business
decision making, sustainability reporting and ESG investors.

2. Digital preparedness - evaluate the company’s preparedness for digital data submission (XBRL).

3. Assurance of data and disclosure - CSRD assurance and competency requirements require
GHG Accounting for which norms such as ISO14064-3 and ISO 14065 can be leveraged.

4. Alignment with the CSRD requirement for Climate Transition Plans and TCFD to strengthen
risk assessment and reporting on climate related physical and transition risks.

5. Alignment with the CSRD requirement for EU Taxonomy alignment in future and growth
of tracking and disclosure on sustainable market activities including turnover, CAPEX, OPEX,
Mergers & Acquisitions (M&A) and investments.
 Unpacking CSRD: A Guide for Business 47

4.5 Double Materiality Matrix and Results Analysis

The Double Materiality matrix (below) provides a visual representation of the material
environmental and social impacts of the company’s operations. The impacts descriptions
align with the ESRS requirements, which often result in some new impact areas that may
not have been as visible in previous materiality assessments.

It also includes the potential financial impact of these material sustainability issues on
the company’s financial wellbeing. The matrix is based on data gathered and analysed
through the desktop review and stakeholder engagement processes. The material topics
are plotted with financial materiality along the x-axis and impact materiality along the
y-axis as illustrated. The matrix is an essential stepping stone to prioritise sustainability
actions in the business and inform the sustainability roadmap and action plan.

5. Very High
Impact
IMPACT MATERIALITY

4. High Impact

3. Moderate
Impact

2. Low Impact

1. Very Low
Impact

1. Very Low 2. Low 3. Moderate 4. High 5. Very High

Impact Impact Impact Impact Impact

FINANCIAL MATERIALITY

Source: Based on EFRAG DM Guidance

 Unpacking CSRD: A Guide for Business 48

Below are two examples of how a company’s DM matrix can look. While EFRAG gives
guidance on the structure, the visualisation of material topics can vary, in part depending
on the outcomes of the DMA.

Example 1
Environmental
1. Waste

2. Environmental management
compliance
Critical

3. Circular economy

11 4. Water

7 8 5. Energy efficiency and

comsumption
Significant

6 6. Emissions and environmental

impact
3 5 12 7. Biodiversity
IMPACT MATERIALITY

2 18 4 8. Climate change
13
14
Important

10
17 15 Social
9. Impact on communities
1 16
10. Employment practices
9
11. Sustainability products a
 nd
Informative

services

12. Supply chain

13. Human rights

14. Occupational health and safety

Minimal

15. Diversity and inclusion

Governance
Minimal Informative Important Significant Critical 16. Privacy and security

FINANCIAL MATERIALITY 17. Value chain management

18. Marketing and labelling

Unpacking CSRD: A Guide for Business 49

Example 2

Digital Materialty Assessment Results

Impact high or very high, financial Impact high or very high, financial
High

risk moderate or lower: risk high or very high:

- General pollution: air, water and - Climate change mitigation,
land pollution adaptation, resilience and transition
- Biodiversity and ecosystems - Responsible sourcing
IMPACT MATERIALITY

- Employees satisfaction and labour - Product safety

rights - Product sustainability
- Occupational health and safety - Talent attraction, training &
development
- Diversity and inclusion

Impact moderate or lower, financial Impact moderate or lower, finiancial

risk moderate or lower: risk high or very high:
- Water and marine resources - Resource use and circularity
- Corporate governance - Digitalisation
- Ethical business conduct
Low

Low FINANCIAL MATERIALITY High

Unpacking CSRD: A Guide for Business 50

CASE STUDY

Cpl
Sustainability plays an increasingly important role in the long-term
success of all businesses. At Cpl, sustainability has been its own
function since 2022 giving us the opportunity to embed it into
business practices and culture. Led by the Chief People Officer
and Sustainability Consultant, our sustainability strategy is “to be
an exemplar for good sustainable business practices, by creating
a positive impact on society, the environment, our people, and our
economy.”

Reporting

In accordance with transparency, we voluntarily release our

Sustainability Strategy and Report annually on our website. The report
includes our carbon reduction plan and commitment to Net Zero by
2045 through 30+ targets underpinned by the following SDGs:
“This assessment was created
• SDG 3 Good Health and Well-Being,
from a review of Cpl policies
• SDG 4 Quality Education, and sustainability documents,
• SDG 8 Decent Work and Economic Growth, stakeholder interviews, a
companywide survey and a
• SDG 10 Reduced Inequalities and
workshop with our GreenWorks
• SDG 13 Climate Action. Committee.”

We also publicly disclose to CDP and report to EcoVadis, the ESG – Cpl
risk and compliance assessment platform, to ensure best practice is
followed.

Double Materiality Assessment (DMA)

Our sustainability strategy is informed by the results of a DMA, first

conducted in 2022. It aligns with our strategic pillars.

This DMA allowed us to identify the most important issues for our
business, and the organisation’s impact on society, the environment,
our people, and the economy. This asessment was created from a
review of Cpl policies and sustainability documents, stakeholder
interviews, a companywide survey and workshop with our GreenWorks
Committee.

The results of our DM analysis emphasise the importance of employee

engagement in the organisation’s future sustainability work, along
with a requirement for additional training to be provided to our people.
We will be updating our DMA to give us a greater understanding of
our dependencies, impacts, risk and opportunities (DIROs) as well as
giving clarity on which sustainability matters should be reported on in
the CSRD report.
Unpacking CSRD: A Guide for Business 51

Cpl Sustainability Journey

Having begun in 2018 with a strong focus on DE&I and CSR, we

have evolved our efforts with a strong investment into reporting,
decarbonisation, awareness, volunteering within our local communities
and launching our GreenWorks Committee.

In 2023, we:

• Expanded our footprint to include all material countries including

relevant scope 3 emissions categories.

• Measured the carbon footprint associated with providing

recruitment services.

• Transitioned more offices to renewable electricity.

• Implemented a new data retention policy- removing huge amounts

of data from being hosted and stored.

• Launched our Sustainable Business Travel Policy to encourage

more green travel options.

• Connected with our landlords across all 46 offices to establish

areas of biodiversity at each office.

• Secured ISO 14001 accreditation for our Environmental

Management System (EMS) in October 2023.

Responsible Sourcing

We have set targets to include sustainability criteria in our tender

documents, to assess our supply chain on their maturity, and to
collaborate and educate our suppliers on this topic.

Governance

A strong governance framework is key to delivering the strategy.

We have a core team in place who actively work across all areas of
sustainability.

The team is made up of key members of our Sustainability Steering

Group and GreenWorks Committee. The output of this team is
overseen by the Executive Committee which also considers the key
areas of leadership and ethics. Our CEO and the Group Executive
Team have management responsibility for the business, and this is
overseen by the Board of Directors.
Unpacking CSRD: A Guide for Business 52

4.6 Sustainability Statement

Sustainability information reported under CSRD should be part of the management
report, ensuring that financial and sustainability reporting are connected and informative
for all stakeholders. This integration is essential for creating a fully informative report.

The sustainability information should be included in the company’s annual report as a

Sustainability Statement. The data used for the Sustainability Statement must align with
the same period as the financial year of the annual report.

The structure of the Sustainability Statement is defined in the Appendix of CSRD16:

1. General Disclosures First

» Start with ESRS 2 General Disclosures. These should be presented in the first
chapter of the Sustainability Statement.

2. ESG Disclosures

» Following the General Disclosures, include specific ESG Disclosures.

3. Topic-Specific Disclosures

» Address material IROs related to specific topics in their respective sections.

4. Non-Material Disclosures

» If a company concludes that a disclosure requirement in the topical standards

is not material, it must provide a detailed explanation. This explanation should
cover the materiality assessment and why the specific standard or data point is
considered non-material.

By following this structure, companies’ sustainability reporting is thorough and aligns

with CSRD requirements17.

16 CSRD Delegated Regulation – Appendix D, F

17 CSRD Delegated Regulation – Appendix D, F
Unpacking CSRD: A Guide for Business 53

Management Report

Analysis of the development & Description of the

performance of the undertaking’s principal risks and
business and its position uncertainties

The undertaking’s Corporate

likely future Governance
developments Statement

Sustainability Statement

1. General Information 3. Social Information

ESRS 2 General Disclosures ESRS S1 Own Workforce

• Specific topical Disclosure Requirement from • Impact, Risk, and Opportunity management
topical ESRS and Metrics and Targets Disclosure
Requirement from ESRS S1
• Additional Disclosure Requirement from
sector specific ESRS • Additional Disclosure Requirement from
sector specific ESRS
• List of Disclosure Requirements complied
with • Potential additional entity specific information

• Table of all the datapoints deriving from other ESRS S2 Workers in the Value Chain
EU Legislations
• Impact, Risk, and Opportunity management
2. Environmental Information and Metrics and Targets Disclosure
Requirement from ESRS S2
Disclosures pursuant to Article 8 of
• Additional Disclosure Requirement from
Regulation 2020/852 (Taxonomy Regulation)
sector specific ESRS
ESRS E1 Climate Change • Potential additional entity specific information

• Impact, Risk, and Opportunity management ESRS S4 Consumers and End-Users

and Metrics and Targets Disclosure
Requirement from ESRS E1 • Impact, Risk, and Opportunity management
and Metrics and Targets Disclosure
• Additional Disclosure Requirement from Requirement from ESRS S4
sector specific ESRS
• Additional Disclosure Requirement from
• Potential additional entity specific information sector specific ESRS
ESRS E1 Resource Use and Circular Economy • Potential additional entity specific information

• Impact, Risk, and Opportunity management

and Metrics and Targets Disclosure
4. Governance Information
Requirement from ESRS E5 ESRS G1 Business Conduct
• Additional Disclosure Requirement from
• Impact, Risk, and Opportunity management
sector specific ESRS
and Metrics and Targets Disclosure
• Potential additional entity specific information Requirement from ESRS G1

• Additional Disclosure Requirement from

sector specific ESRS

• Potential additional entity specific information

CSRD ESRS Reporting Statement, illustrating an example of selected ESRS (Source: CSRD Delegated Regulation)
Unpacking CSRD: A Guide for Business 55

5. Impact, Risk and Opportunity

Assessment
What does this section cover?
This section sets out how to conduct an effective Impact, Risk
and Opportunity (IRO) assessment with illustrative examples
from Sisk.

5.1 Commencing an Assessment

To begin an effective assessment for CSRD compliance, organisations must first define
the scope and objectives that align with their sustainability goals.

A cross-functional team should be established, ideally from departments such as finance,

operations, sustainability, and compliance. This ensures a holistic approach to identifying
and managing both risks and opportunities.

The next step is to establish and develop a structured framework to guide the entire
assessment process. This framework should address specific risks and identify potential
opportunities within the organisation’s operations and align with its strategic objectives.
It should also clearly differentiate between disclosures that are mandatory under CSRD
and disclosures that are critical due to their material impact on the organisation or
environment.

5.2 Risk Identification and Assessment

With the framework established, the team can systematically identify and assess risks
by gathering and analysing data on ESG factors. This process employs techniques such
as scenario analysis, stakeholder engagement, and benchmarking against industry
standards. Each identified risk should be evaluated from two perspectives: its potential
impact on the organisation’s financial performance (financial materiality) and its effects on
society and the environment (impact materiality). This dual perspective aids in prioritising
which risks to consider based on their significance to the organisation and their broader
societal or environmental impact.

TOP TIP:
It is crucial for organisations to integrate these risk assessments into their
regular review cycles, ensuring that risk management is responsive and
adaptive to any changes in external conditions or business operations. By
embracing the DM concept, organisations can more effectively align their
strategies with CSRD requirements, addressing both the risks posed by
ESG factors to their operations and the impacts of their operations on these
factors.
Unpacking CSRD: A Guide for Business 56

5.3 Highlighting Opportunities

In parallel with the risk assessment, identifying opportunities that arise from sustainable
practices is vital. Sustainable products and services can lead to significant competitive
advantages, operational efficiencies, and market differentiation. For instance,
transitioning to renewable energy sources not only cuts costs but also appeals to
environmentally conscious consumers and investors.

Documenting and analysing case studies where sustainability initiatives have led
to business growth can serve as a blueprint for further integration of sustainable
practices. These success stories demonstrate the tangible benefits of sustainability,
encouraging broader adoption across the organisation. By undertaking these
assessments, organisations can manage their risks effectively while also capitalising
on new opportunities. This comprehensive approach not only ensures compliance with
CSRD but also leverages sustainability as a strategic advantage, promoting long-term
organisational resilience and growth.
Unpacking CSRD: A Guide for Business 57

CASE STUDY

Sisk
In December 2020 we launched our 2030 sustainability roadmap that
included five themes and 21 targets, supporting the UNSDGs. This
ten-year roadmap also meant that we committed to updating our
stakeholders on an annual basis about progress and performance
against the ambitious targets.

As a privately held, family-owned business, sustainability reporting

was not a legislative requirement under the Non-Financial Reporting
Directive. However it was clear through horizon scanning, stakeholder
engagement, client expectations, the introduction of gender pay
reporting and the carbon reduction reporting in the UK, sustainability
reporting would soon become the norm for businesses like Sisk.

For years there has been a myriad of standards, disclosures and “At the heart of reporting is
frameworks for sustainability reporting, alongside rankings, ratings and transparency and the purpose
global commitments – at times it becomes a difficult place to navigate, of reporting is not just to meet
to understand what is relevant and adds value to an organisation. legislative requirements but
to understand the impacts,
For Sisk, in-depth sustainability reporting across a range of standards risks and opportunities and
was unfamiliar territory, however there was recognition across the to ensure it has a strategy in
business that our approach needed to evolve, with one eye on the place to proactively address
ever-developing CSRD. material issues.”

As such, we published our first Sustainability Report in 2022 (reporting –Sisk

period Jan-Dec 2021). The business decided to align with the
Global Reporting Initiative (GRI), who were an integral stakeholder
in the development of the CSRD and one of the most widely used
sustainability reporting standards globally. At the heart of reporting
is transparency and the purpose of reporting is not just to meet
legislative requirements but to understand the impacts, risks and
opportunities and to ensure it has a strategy in place to proactively
address material issues.

Our most recent double materiality assessment reinforced the

recognition through our roadmap that Climate Change (E1) and Own
Workforce (S1) continue to be key material issues that remain at the
forefront of our sustainability agenda.

Every company’s sustainability journey is unique but there are

common experiences and learnings that can be shared. It is important
to bring all the internal stakeholders together so they understand
why robust and transparent reporting is important, why data integrity
is critical, how reporting should help support an organisation’s
ambitions and progress and why it is not just the responsibility of the
sustainability / ESG team!
Unpacking CSRD: A Guide for Business 58

Our approach to internal stakeholder management centred on

developing a shared understanding and thus a commitment to
ownership through informal discussion and more formal workshop
and programme along with direct engagement through the double
materiality process.

We are in the process of finalising our third GRI aligned sustainability

report. In 2026 we will publish our first CSRD report and are confident
we are in a strong position to be ready for that next stage of reporting
legislation. We are continuously keeping abreast of new developments
related to sustainability reporting, seeking to be at the heart of change.
With operations in Ireland, the UK and wider Europe and with a host of
international clients, we undertake to remain vigilant and continue to
leverage reporting to ensure we are at the forefront of sustainability for
our industry and actively contribute to the wider business community.
Unpacking CSRD: A Guide for Business 60

6. Topics and Datapoints for

Disclosure
What does this section cover?
This section outlines the topics and datapoints that are relevant
for disclosure and highlights which ESRS each topic and
datapoint is associated with.

6.1 ESRS topics and sub-topics

This table illustrates the “topics, sub-topics and sub-sub-topics” for each ESRS and
provides a guideline to collect the necessary data related to the data points for ESG
disclosure.

Environmental
ESRS Number Topic Sub-topic

• Climate change adaptation

ESRS E1 Climate Change • Climate change mitigation

• Energy

• Pollution of air, water, soil, living organisms and food

resources

ESRS E2 Pollution • Substances of concern

• Substances of very high concern

• Microplastics

• Water consumption & withdrawals

Water and Marine • Water discharges

ESRS E3
Resources • Water discharges (in the ocean)

• Extraction and use of marine resources

• Direct impact drivers of biodiversity loss

Biodiversity and • Impacts on the state of species

ESRS E4
Ecosystem • Impacts on the extent and condition of ecosystems

• Impacts and dependencies on ecosystem services

• Resources inflows, including resource use

ESRS E5 Circular Economy • Resource outflows related to products and services

• Waste
Unpacking CSRD: A Guide for Business 61

Social
ESRS Number Topic Sub-topic

• Working conditions (incl. adequate wages, working time,

social dialogue, health and safety, collective bargaining,
work-life balance)

• Equal treatment and opportunities for all (incl. diversity,

training and skills development, gender equality,
ESRS S1 Own Workface
equal pay, employment and inclusion of persons with
disabilities, measures against violence and harassment
in the workplace)

• Other work-related rights (incl. child labour, forced

labour, privacy)

• Working conditions (incl. adequate wages, working time,

social dialogue, health and safety, collective bargaining,
work-life balance)

• Equal treatment and opportunities for all (incl. diversity,

Workers in the training and skills development, gender equality,
ESRS S2
Value Chain equal pay, employment and inclusion of persons with
disabilities, measures against violence and harassment
in the workplace)

• Other work-related rights (incl. child labour, forced

labour, water & sanitation)

• Communities’ economic, social and cultural rights (incl.

housing, food, water & sanitation, land and security
related impacts)

Affected • Communities’ civil and political rights (incl. freedom of

ESRS S3
Communities expression, freedom of assembly, impacts on human
rights defenders)

• Rights of indigenous people (incl. self-determination,

free, prior and informed consent, cultural rights)

• Information-related impacts for consumers and/or end-

users (incl. privacy, freedom of expression, access to
information)

Consumer and • Personal safety of consumers and/or end-users (incl.

ESRS S4
End-Users health and safety, security of children and persons)

• Social inclusion of consumers and/or end-users (incl.

non-discrimination, access to products and services,
responsible marketing practices)

Governance
ESRS Number Topic Sub-topic

• Corporate culture

• Protection of whistle-blowers

• Animal welfare
Business • Political engagement and lobbying activities
ESRS G1
Conduct
• Management of relationships and suppliers including
payment practices

• Corruption and bribery (prevention and detection

including training, incident reporting)
Unpacking CSRD: A Guide for Business 62

6.2 Datapoints
All ESRS ESG topics and subtopics listed above consist of several disclosure
requirements which have several data points (DPs) each that need to be disclosed, some
of the data points are mandatory or voluntary disclosures. A datapoint encompasses
a clearly separable and specific piece of information required by the ESRS Disclosure
Requirements (DRs). These can be numerical, quantitative datapoints (percentage,
monetary); non-numerical but comparable types (date, year, semi-narrative elements)
or narrative types (text).

The full list with all 1000+ datapoints is in the CSRD implementing legislation and can be
found on the EFRAG website - EFRAG (sharefile.com). Supplementary Implementation
Guidance - EFRAG IG 3: Detailed ESRS Datapoints and accompanying Explanatory Note
supports this. Companies should be aware that the list is not intended to be used as a
starting point of the DMA, but more to guide the gap analysis and prepare for disclosure
once the disclosure requirements are clear.

EFRAG IG 3 states that 161 datapoints are mandatory irrespective of the DMA.
A further 622 datapoints are subject to the DMA. These are illustrated below.

EFRG IG 3: List of ESRS datapoints - Explanatory note below

ESRS - Delegated Act (31 July 2023)

Number of “shall” DPs (without MDR-PAT&M) Number of
ESRS Irrespective of MA Subjecy to MA Total “may” DPs
ESRS 2 127 127* 12
E1 16 171 187 15
E2 3 41 44 20
E3 2 25 27 18
E4 11 43 54 65
E5 2 40 42 19
S1 127 127 55
S2 47 47 18
S3 45 45 18
S4 44 44 19
G1 39 39 10
Total 161 622 783 269
Total DP (%) 21% 79% 100%
*7 Datapoints are excluded from the count as subject to phased in (ESRS 2 BP2 par. 17)

ESRS - Delegated Act (31 July 2023)

Minimum Disclosure Requirements (MDR-PAT&M) Per Sustainability Matter and per PAT*

Disclosure This table illustrates the datapoints in relation with Minimum

Requirements Disclosure Requirements (MDR) on Policies, Actions, Targets
and Metrics (PAT&M) according to ESRS 2 Chapter 4.2.
MDR-P 6
MDR-A 12 These are considered for the disclosures when the undertaking
MDR-T 13 has adopted PAT related to material sustainability matters.

MDR-M 3

*Excluded Datapoints to be reported if the undertaking has not adopted policies and/or actions or set any measurable outcome-
oriented targets (ESRS 2 chapter 4.2 MDR)
Unpacking CSRD: A Guide for Business 63

6.3 Datapoint Examples

Examples of the datapoints for ESRS E1 Climate Change and ESRS S1 Own Workforce
are provided below.

ESRS E1 Climate Change – this consists of 9 disclosure requirements, with 16 data

points for DR 1.1 – Transition plan for climate change mitigation.

Disclosure
ESRS ID Data Point Data Type
Requirement

Disclosure of transition plan for climate change

E1 E1.1 E1-1_01 narrative
mitigation

Explanation of how targets are compatible with limiting

E1 E1.1 E1-1_02 of global warming to one and half degrees Celsius in narrative
line with Paris Agreement

E1 E1.1 E1-1_03 Disclosure of decarbonisation levers and key action narrative

Disclosure of significant operational expenditures

E1 E1.1 E1-1_04 (Opex) and (or) capital expenditures (Capex) required narrative
for implementation of action plan

E1 E1.1 E1-1_05 Financial resources allocated to action plan (OpEx) monetary

E1 E1.1 E1-1_06 Financial resources allocated to action plan (CapEx) monetary

Explanation of potential locked-in GHG emissions

from key assets and products and of how locked-in
E1 E1.1 E1-1_07 narrative
GHG emissions may jeopardise achievement of GHG
emission reduction targets and drive transition risk

Explanation of any objective or plans (CapEx, CapEx

plans, OpEx) for aligning economic activities (revenues,
E1 E1.1 E1-1_08 narrative
CapEx, OpEx) with criteria established in Commission
Delegated Regulation 2021/2139

E1 E1.1 E1-1_09 Significant CapEx for coal-related economic activities monetary

E1 E1.1 E1-1_10 Significant CapEx for oil-related economic activities monetary

E1 E1.1 E1-1_11 Significant CapEx for gas-related economic activities monetary

Undertaking is excluded from EU Paris-aligned

E1 E1.1 E1-1_12 semi-narrative
Benchmarks

Explanation of how transition plan is embedded in and

E1 E1.1 E1-1_13 aligned with overall business strategy and financial narrative
planning

Transition plan is approved by administrative,

E1 E1.1 E1-1_14 semi-narrative
management and supervisory bodies

E1 E1.1 E1-1_15 Explanation of progress in implementing transition plan narrative

Date of adoption of transition plan for undertakings not

E1 E1.1 E1-1_16 Year
having adopted transition plan yet
Unpacking CSRD: A Guide for Business 64

S1 Own Workforce consists of 17 Disclosure requirements, with 10 data points

for disclosure requirement S1.7 - Characteristics of non-employee workers in the
undertaking’s own workforce.

Disclosure
ESRS ID Data Point Data Type
Requirement

S1 S1.7 S1-7_01 Number of non-employees in own workforce Decimal

Number of non-employees in own workforce -

S1 S1.7 S1-7_02 Decimal
self-employed people

Number of non-employees in own workforce - people

S1 S1.7 S1-7_03 provided by undertakings primarily engaged in Decimal
employment activities

Undertaking does not have non-employees in own

S1 S1.7 S1-7_04 semi-narrative
workforce

Disclosure of the most common types of non-

employees (for example, self-employed people,
people provided by undertakings primarily engaged in
S1 S1.7 S1-7_05 narrative
employment activities, and other types relevant to the
undertaking), their relationship with the undertaking,
and the type of work that they perform.

Description of methodologies and assumptions used to

S1 S1.7 S1-7_06 narrative
compile data (non-employees)

Non-employees numbers are reported in head count/

S1 S1.7 S1-7_07 semi-narrative
full time equivalent

Non-employees numbers are reported at end of

S1 S1.7 S1-7_08 semi-narrative
reporting period/average/other methodology

Disclosure of contextual information necessary to

S1 S1.7 S1-7_09 narrative
understand data (non-employee workers)

Description of basis of preparation of non-employees

S1 S1.7 S1-7_10 narrative
estimated number
Unpacking CSRD: A Guide for Business 66

7. Grants and Financial Support

What does this section cover?
This section highlights a broad range of grants and supports
available to businesses who seek to become more sustainable.

7.1 Grants and Financial Supports available for Green

Business Initiatives
In alignment with Ireland’s targets to reduce carbon emissions, a variety of grants and
financial supports are accessible for businesses committed to embracing sustainable
practices. The launch of the government’s National Enterprise Hub provides businesses
with a single source for all government supports available to become more sustainable.
Some of the broad range of available grants and supports include:

Enterprise Ireland and IDA Ireland grants available:

Programme Grant Available Eligibility

€1,800 grant for advisory services to develop initial

Climate Action Voucher sustainability, decarbonisation, circular economy strategy Enterprise Ireland clients
and action plan.

Up to €5,000 (80% grant) for hiring Green Service Providers Enterprise Ireland and IDA
to help companies introduce environmental best practices Ireland clients;
GreenStart Grant
and structures and lay foundation for future environmental Micro-enterprises and small
projects. enterprises in certain sectors

Up to €50,000 (up to 50% grant) for hiring environmental

experts to develop a high level of environmental Enterprise Ireland and IDA
GreenPlus Grant
management capabilities, drive environmental efficiencies Ireland clients
and achieve improved sustainability.

Up to €35,000 (up to 50%) of eligible costs to hire consultant

to help with development and implementation of strategic
Strategic Consultancy Enterprise Ireland clients
initiatives and company plans in areas of sustainability and
decarbonisation.

Capital Investment for Up to €50,000 (up to 50% of eligible costs) to support

Enterprise Ireland clients,
Energy Monitoring & companies to put monitoring and targeting systems in place
Manufacturing businesses
Tracking Systems to begin accounting for their carbon footprint.

Capital Investment Up to €1 million (30-50% of eligible costs) to support

Enterprise Ireland clients,
for Decarbonisation investment in carbon reducing technologies in manufacturing
Manufacturing businesses
Processes combustion processes.

Enterprise Ireland and IDA

€5,000 per SME to explore business opportunity in the area
Innovation Vouchers Ireland clients, Small and
of sustainability and decarbonisation.
medium enterprises

Up to €35,000 (50% of eligible costs) to support planning of Enterprise Ireland clients,

Exploring Innovation research, development or innovation projects in the areas of Businesses exploring
sustainability and decarbonisation. sustainability innovation

Enterprise Ireland and IDA

Grant based on project type and company size to develop
Research, Development Ireland clients, Businesses
new or improved products, services or processes in the
& Innovation Fund developing sustainable
areas of sustainability and decarbonisation.
solutions
Unpacking CSRD: A Guide for Business 67

Other Financial Supports

Supporter Programme Grant Available Eligibility

Energy Efficiency

Local Enterprise Energy Efficiency Up to €5,000 for energy-efficient technology Small and medium
Office Grant and equipment enterprises

Up to €3,000,000 to fund energy-efficient

SEAI (Sustainable Businesses planning an
EXEED Grant investment projects to optimize energy
Energy Authority investment in an energy
Scheme performance and reduce operational energy/
of Ireland) project
costs and carbon emissions

Tax incentive scheme that allows to deduct

Accelerated Capital Sole trader, farmer, business
SEAI full cost of energy-efficient equipment from
Allowance (ACA) that pays corporate tax in IE
profits in year of purchase

Grant (up to 30%) to help businesses adopt

Commercial, industrial,
Support Scheme renewable heating systems, i.e. installation
agricultural, district heating,
SEAI for Renewable Heat grant for commercial heat pump, operational
public sector, and other non-
(SSRH) support for biomass and biogas heating
domestic heat users
systems

National Up to €20,000 or €25,000 for wheelchair

Electric SPSV
Transport accessible small public service vehicles SPSV licence holders
(eSPSV) Scheme
Authority (NTA) (SPSV)

Businesses, public sector

Solar PV Scheme Up to €162,600 to help businesses install
bodies, community
SEAI (Non-Domestic solar PV panels to generate electricity on site
organisations, Non-profit
Microgen Grant) (systems up to a mx 1000kWp)
societies

Sustainability Training and Mentoring

Free programme that helps small businesses

Local Enterprise Small and medium
Green for Business take the first step towards becoming more
Office enterprises
sustainable, giving access to a consultant

7.2 Other helpful tools

• Government of Ireland ‘Climate Toolkit 4 Business’ website - check company’s carbon
footprint, get practical advice on how to reduce it, learn about sustainable, cost-
efficient products and services

• EPA Tool for Resource Efficiency - overview of company’s resource efficiency relating
to water, waste and energy and get action plan for resource efficiency

• Water conservation for business | Conservation | Uisce Éireann (formerly Irish Water)

• SEAI Energy Academy

• Skillnet Ireland Climate Ready Academy

• Climate Action: A toolkit for business

Unpacking CSRD: A Guide for Business 68
Unpacking CSRD: A Guide for Business 69

8. Further Resources
CSRD Legislation

• Corporate Sustainability Reporting Directive - European Commission (europa.eu)

• Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing

Directive 2013/34/EU of the European Parliament and of the Council as regards
sustainability reporting standards (europa.eu)

• EUR-Lex - 02013L0034-20240109 - EN - EUR-Lex (europa.eu)

• Irish implementing legislation

Additional Supports by Government of Ireland

• Corporate Sustainability Reporting - DETE (enterprise.gov.ie) and csrd@enterprise.

gov.ie for enquiries

• Presentations from webinar on Corporate Sustainability Reporting Directive July 2023

(enterprise.gov.ie)

• Department of Enterprise, Trade and Employment Responsible Business portal -

https://enterprise.gov.ie/en/what-we-do/the-business-environment/responsible-
business/

CSRD Guidance
In support of the CSRD law, EFRAG continue to publish guidance and will issue sector
specific standards as detailed in 3.6.

ESRS Implementation Guidance documents to date include:

• EFRAG IG 1: Materiality Assessment

• EFRAG IG 2: Value Chain

• EFRAG IG 3: Detailed ESRS Datapoints and Accompanying Explanatory Note

• Sustainability Reporting XBRL Taxonomies - EFRAG

Additional EFRAG resources include:

• The EFRAG FAQ on implementation questions to date provides practical supports

with regular updates EFRAG ESRS Q&A Platform - EFRAG

• EFRAG Sector Specific ESRS - EFRAG.

EU Supports:

• Questions on SFDR & other financial regulatory requirements re CSRD compliance

Q&A adoption of European Sustainability Reporting Standards (europa.eu)
Unpacking CSRD: A Guide for Business 70

Further Business Supports:

• Davy Horizons 1 pager summary on CSRD - The Corporate Sustainability Reporting

Directive (CSRD) and what it means for you (davy.ie)

Assurance Standards:

• ISAE 3000 International Standard on Assurance Engagements ISAE3000 Revised,

Assurance Engagements Other Than Audits or Reviews of Historical Financial
Information.

• ISAE 3410: Assurance Engagements on Greenhouse Gas Statements, Assurance on a

Greenhouse Gas Statement | IAASB

• International Standard on Sustainability Assurance (ISSA) 5000, General Requirements

for Sustainability Assurance Engagements, Understanding International Standard on
Sustainability Assurance 5000 | IAASB
Unpacking CSRD: A Guide for Business 71

With appreciation to the following Ibec members who have contributed their
experiences to this toolkit:

Project Team

Dr. Dorothy Maxwell, FICRS Dr. Kara McGann

Head of Sustainability & ESG Advisory Head of Skills & Social Policy

Dr. Helen Kavanagh Patrick Duffy

Associate Director of Sustainability Senior Executive - Policy

Gina Mester Alan Sherlock

Senior Sustainability Associate Senior Executive - Strategic Lobbying & Campaigns

Ellen Keating
Sustainability Business Executive
Unpacking CSRD: A Guide for Business 72

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