From Data Set to Report: What Can Be Automated and What Can’t
Once the data from all subsidiaries is available, the phase begins that many companies consider to be the actual report: the writing process. In fact, this is the phase with the highest degree of automation, because a large portion of the information comes from the database and another large portion is carried forward from the previous year. The revised European Sustainability Reporting Standards (ESRS) provide more flexibility than the previous version. This article describes the freedoms the new standards offer, what automation and AI actually handle in the reporting process, and what you need to keep in mind when preparing a second language version.
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.
For the first time, the revised standards allow for a different organizational structure
The previous version organized the sustainability statement into four sections: general information, environment, social issues, and governance. The revised version retains the same order but expressly allows for deviations from it, provided the company provides a reasoned explanation and complies with the other provisions of the chapter. This is new.
In addition, there are four other areas of flexibility that, in practice, are more significant than the structure itself:
- Appendices and separate subsections are permitted, both to provide detailed information and to improve readability—for example, for tables of contents, cross-reference tables, and reference tables.
- The disclosures required under Article 8 of the EU Taxonomy Regulation may be included in a separate appendix within the management report.
- A summary may be included within the statement or provided by referring to a summary elsewhere in the management report.
- Additional information from other legal documents or from GRI and ISSB standards may be included, even if it is not material, as long as it is identified as not deriving from the materiality analysis and does not obscure the material information.
The question of how much detail you need to include in your reporting has also been clarified. The level of aggregation depends on the level at which material differences in impacts, risks, and opportunities arise. The level of detail in the materiality analysis does not require you to report at the same level of depth.
Context: The most important point for practical purposes is a clarification that is easily overlooked: The requirement for accurate representation applies to the sustainability statement as a whole, not to each individual data point. This takes some of the pressure off the debate over whether a single piece of information is, on its own, sufficiently complete.
References eliminate repetition when five conditions are met
Instead of repeating information that is already provided elsewhere, the ESRS allow for incorporation by reference. Permitted sources include another section of the management report, the annual financial statements, the corporate governance statement, the compensation report, the uniform registration form, and disclosures under the Equity Regulation. In addition, the EMAS environmental report may be included, provided that the same preparation criteria apply—that is, the scope of consolidation and the treatment of the value chain are consistent.
Five conditions must be met collectively for this. The included information must be a separate element clearly associated with the respective disclosure requirement. It must be published before or at the same time as the management report. It must be available in the same language as the sustainability statement. It must be subject to at least the same level of audit assurance as the rest of the report, although the entire source document does not need to be audited. And it must meet the same technical requirements for digitization.
Two points regarding this that regularly cause confusion in projects: Cross-references within the statement—such as from a thematic chapter to the organization’s own appendix—are expressly not considered incorporated by reference and are not subject to these conditions. And incorporated disclosures are part of the sustainability statement and are therefore included in the scope of the audit. They must be identified separately in the list of disclosure requirements applied.
A large portion of the report is repeated year after year
The second reporting season has shown how consistent the reports have remained over the years. The EFRAG report “State of Play 2026” dated July 1, 2026, which analyzes 905 audited sustainability statements for the 2025 fiscal year, summarizes it as follows: The materiality, structure, scope, and profile of the statements have largely been carried over from the previous year, with no fundamental shifts.
The figures support this. When comparing the same companies across both years, the report’s length decreased from 108 to 103 pages; in Germany, it fell from 117 to 104. On average, the sustainability report accounts for 34% of the total number of pages in the annual report. Eighty-two percent of the companies updated their materiality analysis rather than creating a new one, and the material topics remained virtually unchanged: climate change at 99%, the company’s own workforce at 99%, and corporate governance at 95%.
In terms of report preparation, this means that what changes between two reporting years are primarily the figures, not the structure, and rarely the descriptions of concepts, processes, and responsibilities. A report that is rewritten from scratch every year squanders this advantage and also creates inconsistencies with the previous year’s report, which will be noticed during the audit.
Context: Only 6% of companies provide a summary; in Denmark, the figure is 18%; in Belgium, 16%; and in Spain, 15%. Since the revised standards explicitly permit this, it is one of the few ways a report can stand out from the crowd with minimal effort.
What Automation Actually Handles in the Reporting Process
Automation doesn’t replace the message; it simplifies the path to getting there. These four automation measures offer real benefits:
Key figures are pulled from the database and incorporated into the text. Each number in the report links to the corresponding data point rather than being typed out. If the value changes after being published, it updates automatically in all instances, including tables and charts.
Prior-year figures and variances are generated automatically. Comparative figures are automatically carried over. Manually maintained prior-year columns are one of the most common sources of error.
Consistency checks are running in the background. Totals, units, percentages over 100, and discrepancies between the text and the table can be detected automatically before anyone reads them.
The list of disclosure requirements is derived from the report, not created separately from it. The overview of the required disclosures—including source references and separate labeling of the information incorporated by reference—is a byproduct when the report and the data point catalog are linked, and a tedious manual task when they are not.
Reuse across frameworks has the same effect. Once you’ve entered the metric with its definition, scope of consolidation, and time period, it’s also compliant with the EU Taxonomy, IFRS S1 and S2, or the voluntary standard. Our article on the interoperability of sustainability standards describes the official classifications available and their scope.
AI helps with the text, not with responsibility
There are currently no regulatory or professional guidelines regarding the use of artificial intelligence in the preparation of a sustainability report. Neither the ESRS nor the CEAOB audit guidelines mention the term, and the EU Regulation on Artificial Intelligence does not classify the preparation of sustainability reports as a high-risk application. The most relevant provisions of the regulation for users are the requirements regarding employees’ AI competence and the transparency obligations.
However, there is one statement you should be aware of. On May 21, 2026, the Chamber of Public Accountants published questions and answers regarding the use of artificial intelligence in the practice of public accounting. It states: If companies use artificial intelligence to provide information, the auditor must independently assess whether this information is sufficiently reliable for the purpose of the engagement. The fundamentally critical stance remains unchanged. Anyone who uses AI in the reporting process should therefore document where and how it is used, because they may be asked specifically about this.
It makes sense to use this approach when the problem lies in the language itself, not in the message:
- Initial drafts of descriptive information based on the documented concepts, measures, and objectives, which are then reviewed by subject matter experts.
- Standardization of terminology and wording across chapters contributed by different departments.
- Translation into the second language version, with a final technical review of the terms defined in the standards.
- Compare the report with the previous year’s report to identify statements that are outdated in terms of content.
EFRAG itself serves as evidence that machine-based analysis is becoming established in this field: The analysis of the 905 disclosures for the “State of Play 2026” report was conducted using a generative AI developed in-house, with the results manually verified on a 5% sample. It is precisely this combination of automated preliminary work and documented quality assurance that serves as the model that has also proven effective within the company.
Two language versions require a clear hierarchy
Corporations with an international workforce and international investors generally want the report in German and English. Legally, the two versions are not equivalent.
The annual financial statements, management report, and auditor’s report must be disclosed in German pursuant to Section 325(1), first sentence, of the German Commercial Code (HGB). The German version is therefore the authoritative one and is the subject of the audit. An English version is an additional, non-mandatory publication. Section 328(2) of the German Commercial Code (HGB) applies to it: A heading must indicate that this is not a publication in the form required by law, and an auditor’s report may not be included.
Two practical implications of this are:
Translation is not a subsequent process, but rather a parallel track. If a value or a sentence in the German version changes during the final review, the English version must be updated accordingly. If both versions are generated from the same database, this happens automatically for the numbers; for the text, however, a comparison is required.
References only work within a single language. Because embedded documents must be in the same language as the sustainability statement, an English-language document cannot be embedded in a German statement by means of a reference.
The requirement for electronic labeling has been suspended for the time being
One change in the Omnibus Package directly affects reporting. Directive (EU) 2026/470 clarifies that companies are not required to mark up their sustainability reports as long as the relevant provisions have not been adopted through the associated delegated regulation. The requirement for a standardized electronic reporting format for the management report remains unaffected.
Clarification: This postpones the timing, not the task itself. The designation remains part of the audit scope as soon as it takes effect, and it requires that information can be unambiguously mapped to the elements of the taxonomy. Anyone generating the report from a structured database already has this mapping in place. Our article on ESRS-xBRL tagging describes the background.
What You Should Prepare for Report Generation
Keep numbers and text clearly separated. Every number in the report should refer to a data point; it should not be typed in manually. This is a prerequisite for everything else, from year-over-year comparisons to the second language version.
Decide early on the outline, appendices, and references. A different structure requires a reasoned explanation, and references must meet five criteria. Neither of these can be verified in December.
Determine where AI is used and document it. There is no specific rule regarding this, but the question does come up. You won’t be able to avoid writing a brief description of the procedure anyway; you’ll just end up writing it under time pressure.
Work on the second language version at the same time. With a note in the heading and without an attached audit opinion, and with a comparison after each substantive change.
Generate the list of reporting requirements from the system. It is an essential component and the best way to verify whether the report and the data point catalog are truly linked.
Generate Reports Instead of Writing Them, with CONSUST
A sustainability report is, to a large extent, an analysis of a company’s own data. Our FramesCube CSRD/ESRS software generates it exactly that way: Key metrics are derived from the collected and approved data points, year-over-year comparisons are generated from the time series, text modules are updated rather than rewritten, and the AI-powered generation provides drafts for the descriptive information, which your departments review and approve. The decision on whether a statement is accurate remains with the responsible parties, eliminating the need for manual data transfer in between.
Our article on decentralized data collection explains how the data is gathered; you can find the roadmap leading up to the first report in the white paper “Implementing CSRD Safely: Four Phases to the First Report for 2027.” 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.
