End-to-End CSRD Reporting: From Initial Analysis to Published Report

Most companies required to report under the CSRD for the 2027 fiscal year do not underestimate the scope of the standards, but rather the processes behind them. There are nine steps between the decision to launch the project and the publication of the sustainability statement. Those who deviate from the sequence end up collecting data they won’t need later, or realize in the fall that no one has been assigned responsibility for half of the material topics. This article describes the complete process: what needs to be done, where things often go wrong in practice, and what decisions you need to make for the subsequent steps.

As of September 2026. The information on the revised standards refers to the delegated act dated July 3, 2026. The objection period for the Parliament and the Council expired on September 3, 2026, with no objections raised; the content is therefore finalized, though publication in the Official Journal is still pending. The standards are to be applied to fiscal years beginning on or after January 1, 2027; for the 2026 fiscal year, there is a choice between three options. Our article on decentralized data collection explains where the data comes from.

The schedule has been set, even without a German implementing law

Since the Omnibus Package took effect, companies with more than 1,000 employees and more than €450 million in net revenue are required to file reports. For newly covered companies, the requirement applies to fiscal years beginning on or after January 1, 2027; the first report will therefore be published in 2028. Companies in the first wave that already submit a non-financial statement are subject to separate regulations for the fiscal years 2025 and 2026; this is determined by the German implementing law.

The revised ESRS are to be applied starting in 2027. For the 2026 fiscal year, there are three options: continue using the previous version, adopt the revised standards early, or apply the previous version along with selected simplifications from the new standards. According to the European Commission, the number of mandatory data points will decrease by more than 60%, and the total number by more than 70%. This reduces the scope, but not the process. Materiality analysis, data sources, consolidation, and auditing will remain unchanged in structure and sequence.

Nine stages, and what emerges in each one

Stage	Result	Why it typically fails
1. Project Launch	Scope, Roles, Consolidation Scope, Timeline	The project is solely the responsibility of the sustainability department
2. Double Materiality Analysis	List of Key Topics with Documented Rationale	Result without a clear path to it
3. Gap Analysis	List of data points showing the current status for each item	Comparison with the old list of data points
4. Data Model and Responsibilities	One person in charge and one source per data point	Responsibility at the departmental level rather than the individual level
5. Decentralized Data Collection	Data from all companies and locations	Excel Batch Processing Without Version Information
6. Consolidation	Consolidated figures with a clear basis for calculation	Conversions and Corrections Without a Trace
7. Report Generation	Text and Tables in the Sustainability Statement	Texts are written before the numbers are finalized
8. Exam	Audit Opinion with Limited Assurance	Supporting documents will not be requested until the exam date
9. Publication	Management Report with an Excellent Explanation	Requirement to award honors was scheduled too late

The roadmap, which includes monthly milestones and a maturity assessment, is available in our white paper, “Implementing CSRD Safely: Four Phases to Your First Report for 2027.”

Stages 1 and 2: The project’s launch determines how robust the materiality analysis will be

The process begins with four key decisions that determine the entire course of the project: the scope of consolidation, the roles, the system landscape, and the timeline working backward from the release date.

The scope of consolidation is the often-overlooked aspect here. The sustainability report follows the consolidated financial statements. If you do not assign locations, joint ventures, and companies acquired during the year early on, you will have to correct every single metric later. It is equally important that the finance department and group accounting are involved in the project from the very beginning: The sustainability statement is included in the management report and follows its timeline.

This is the basis of the double materiality analysis. It determines which topics are material—and thus which standards you apply and which data points you collect in the first place. Two observations from previous reporting seasons help put your own results into perspective: On average, companies classify 6.4 of the ten topic-based ESRS as material, and German index companies report an average of 43 impacts, risks, and opportunities, ranging from 6 to 118. Any company that falls significantly outside this range must provide a solid justification in its documentation.

Our comprehensive list of ESRS sustainability topics shows which topics are even worth considering. The process itself is mapped out in our software for double materiality analysis, from stakeholder engagement to assessment documentation.

Breakdown: 82% of companies updated their analysis for fiscal year 2025 based on the previous year rather than starting from scratch, and 67% use a hybrid approach combining top-down and bottom-up elements. Therefore, set up the analysis from the outset as an ongoing process, not as a one-time project.

Stages 3 and 4: The gap analysis translates data points into areas of responsibility

The list of mandatory disclosures and data points is derived from the key topics. The gap analysis compares these with the current status: Which values are already available, what is their quality, from which system, and for which part of the corporate group? The result is not a traffic-light overview, but a to-do list.

Three questions determine their usefulness:

• Does the value exist, or does only the source exist? Energy consumption recorded as an invoice amount in the accounting system is not a data point, but rather a conversion task.
• To which part of the consolidated group does it apply? A value for three out of eleven locations constitutes a gap, not partial fulfillment.
• Who, specifically, is delivering it? Responsibilities at the department level result in non-responses in the survey.

The data model is directly linked to this. Each data point includes a definition, unit, scope of consolidation, reporting period, source, and responsible person. These six pieces of information later serve as supporting documentation during an audit and are also a prerequisite for using the same figure in other frameworks.

That is precisely why it’s worth thinking beyond ESRS requirements at this point. Anyone who also needs to comply with the EU Taxonomy, IFRS S1 and S2, EMAS, or the voluntary standard should set up the mappings now rather than having to do it again later. Our article on the interoperability of sustainability standards describes which official links exist between the frameworks and where they end. The overview of ESG frameworks shows what CONSUST maps for this purpose.

Stages 5 and 6: Decentralized data collection and consolidation are the real challenge

This is where it will be determined whether the schedule can be met. The data is held by plants, regional subsidiaries, the purchasing department, the human resources department, and service providers. It is returned in different units, time frames, and levels of detail.

Experience has shown that four factors contribute most to the result:

Collect data once per value, not once per report. If the same metric is asked separately for the sustainability report, a customer survey, and a rating, three different “truths” emerge.

Provide the suppliers with the context. Anyone who is asked to enter a number needs the definition, the reference period, and an example. Without that, the system returns estimated values that no one recognizes as such.

Assess data quality during data entry. Primary data, secondary data, and estimates must remain distinguishable. The exam specifically asks about this, and it cannot be reconstructed afterward.

Make sure that conversions and corrections are traceable. Most hidden errors arise during consolidation: units, currencies, ownership percentages, and acquisitions and disposals during the year. Every adjustment must be documented; otherwise, the consolidated value will ultimately lack a clear basis.

For emissions data, the value chain must also be taken into account. Scope 3 data can rarely be collected entirely through primary sources, and the amount of information you are permitted to request from business partners with up to 1,000 employees for reporting purposes has been capped since the Omnibus Package: The cap covers only the essential data points of the voluntary standard. Therefore, describe the limitations of your data set rather than concealing them. Our article on the partnership between ISO and the GHG Protocol provides context on how accounting principles are evolving; the data collection process itself is illustrated by Corporate Carbon Footprint and Supply Chain Hub.

Stages 7 and 8: The report is based on the supporting documents, not the other way around

The sustainability statement is divided into general information and environmental, social, and governance (ESG) information. The revised ESRS provide more flexibility regarding presentation, appendices, and cross-references than the previous version. In practice, many companies are already taking advantage of this: 74% of the German reports examined include additional sections, and of these, 77% place the overview of impacts, risks, and opportunities in a separate section.

Three examples from the reports at hand can be directly applied to our first report:

• One IRO table per thematic chapter, including the value-added stage, time horizon, and a distinction between actual and potential impacts. This addresses three of the most common audit findings at once.
• One measurable goal for each key topic. On average, there are 6.4 key issues for every 3.3 issues with specific goals. This gap is immediately apparent.
• First, a brief summary. It’s the exception in the published reports. Anyone who offers one can stand out with very little effort.

The review takes place in parallel. It is conducted on an ongoing basis with limited assurance. The stricter requirement for reasonable assurance, which was included in the original CSRD text, was removed with the Omnibus Package. Four aspects are audited: compliance with the ESRS, the process for determining the reported information, adherence to the labeling requirement in electronic format, and the disclosures required under Article 8 of the EU Taxonomy Regulation. The audit thus focuses not on the text itself, but on the source of the data. Our article on the audit of sustainability reporting describes in detail what auditors require.

Analysis: In the largest German analysis to date, approximately 73% of the reports were audited with limited assurance; for just under 20%, an audit with reasonable assurance was conducted for individual items; and one report was fully audited with reasonable assurance. All audits resulted in unqualified opinions. However, there was still no statutory audit requirement for the 2024 fiscal year. The audits were conducted voluntarily by companies with well-established processes. These figures do not serve as evidence that the audit is easy to pass.

Stage 9: Publication means a status report plus machine-readable markup

The sustainability statement appears in a clearly identifiable section of the management report, not as a separate brochure. This eliminates the flexibility in formatting that existed in earlier voluntary reports, and the timeline for disclosing the annual financial statements applies.

In addition, there is the tagging in the standardized electronic reporting format. This is part of the audit scope and not a step that the agency simply completes at the end: Tagging requires that the data can be unambiguously mapped to the elements of the ESRS-xBRL taxonomy. Our article on ESRS-xBRL tagging describes the technical steps involved.

After publication, the cycle begins anew. The materiality analysis is updated, the data model is adapted to changed standards, and the points from the review meeting are incorporated into the next year’s survey. We’ve compiled a list of areas where published reports consistently fall short in our article on CSRD reports in practice.

What Companies Should Do During the Remaining Preparation Period

Define the consolidation scope before you begin working with the data. Every metric depends on it, and any subsequent change results in rework across all stages.

Document the materiality analysis in a way that auditors will be able to read it. Stakeholders, criteria, thresholds, evaluations, decisions. The result alone is not enough.

Build the data model right the first time. The definition, unit, scope of consolidation, time period, source, and person responsible for each data point are what distinguish a verifiable figure from one that requires explanation.

Try it out using last year’s data. A comprehensive survey based on non-reportable data reveals organizational gaps while they can still be addressed at a reasonable cost.

Plan the assessment and certification as separate tracks. The selection and appointment of examiners, interim results, and the electronic format each require their own deadlines in the reverse schedule.

Manage the entire reporting process in a single system with CONSUST

The effort involved in CSRD projects rarely lies in the writing itself, but rather in the transitions: from the materiality analysis to the list of data points, from decentralized data collection to consolidation, and from consolidation to the documentation for the audit. Our FramesCube CSRD/ESRS software maps this entire process within a single system: materiality analysis with documented rationale, data collection across all companies and locations with designated responsible parties and deadlines, consolidation with traceable conversions, and AI-powered reporting based on the recorded values. You retain control over business decisions; the audit trail is generated as the process unfolds and does not need to be reconstructed prior to the audit.

Our white paper , “Implementing CSRD with Confidence: Four Phases to Your First Report for 2027, ” includes a maturity assessment to help you determine where you stand in the process and what still needs to be done before your first report. For guidance on individual stages, see the framework under CSRD Consulting. Contact us for a no-obligation discussion about your reporting process.

This article presents a professional assessment based on the sources cited, as of September 2026, and is not a substitute for a legal review in individual cases.