CSRD reporting: materiality assessment and then?
Step-by-step guide to CSRD reporting and how ESG software can help with these steps.
- The CSRD requires a structured six-step process: from double materiality assessment through data collection to publication.
- With the Omnibus changes (in force since 18 March 2026), only companies with more than 1,000 employees AND more than €450m net turnover must report.
- The double materiality assessment is the foundation. Everything else follows from it.
- ESG software adds real value at every step, from stakeholder surveys to XBRL tagging.
- Involve your auditor early. Clean documentation throughout the process saves time at audit stage.
The scope of CSRD has changed significantly. Reporting is now mandatory only for companies with more than 1,000 employees AND more than €450m net turnover (both criteria must be met). The previous thresholds (250 employees, "2 of 3 criteria") no longer apply. If you are not in scope, you may still choose to report voluntarily, for example using the VS (Voluntary Standard, based on VSME).
Is your company affected by the Corporate Sustainability Reporting Directive (CSRD) and do you have to prepare a sustainability report in accordance with the European Sustainability Reporting Standards (ESRS)? Or are you dealing with the topic voluntarily or under pressure from your customers or suppliers and don't know where to start?
Numerous companies are currently working on creating the double materiality assessment. This is a good start. But what happens next? This article breaks down the complex requirements of CSRD reporting into manageable individual steps. From the double materiality assessment to data collection and reporting, it explains what needs to be done.
CSRD reporting: step-by-step guide
Creating a CSRD-compliant report requires a methodical approach that ensures all relevant aspects of your company's sustainability performance are accurately captured and reported.
This section gives you a clear overview of the individual steps to take to create a complete and compliant CSRD report that your auditor will approve. Speaking of auditors: involve them early in the process.
- Double materiality assessment: Identify the material sustainability issues (impacts, risks and opportunities) for your company and stakeholders.
- Determine relevant data points: Derive which data points you must report based on the material topics.
- Gap analysis and data collection: Identify what data you already have, then collect what is still missing from internal and external sources.
- Prepare the report: Convert the collected data into a structured, comprehensible report that meets CSRD requirements.
- Review and audit: Have the report checked by an auditor (limited assurance) to confirm accuracy and completeness.
- Finalize and publish: Make any adjustments, obtain management and supervisory board sign-off, and publish within the regulatory deadlines.
Each of these steps is covered in detail below. This structured approach helps you fulfill the CSRD requirements efficiently and present your sustainability efforts transparently. Involve relevant internal and external stakeholders throughout.
1. Double materiality assessment
Double materiality is the central element of CSRD reporting. The materiality assessment is the crucial first step. It involves assessing topics that are significant both from the perspective of your company's impact on the environment and society (impact materiality, inside-out) and from the perspective of how these topics affect your company's financial performance (financial materiality, outside-in).
This holistic approach lets you set priorities and focus on the aspects most relevant to stakeholders and most relevant as risks and opportunities for your business. As part of the CSRD materiality assessment, you must document exactly how you carried out the analysis, which stakeholders were involved, and how the results feed into your sustainability strategy and reporting.
The result of the materiality assessment is typically a list of material topics, often presented graphically as a materiality matrix. This process is more than a regulatory requirement: it gives you valuable input for risk management and sharpens your strategic focus on sustainability. Investors, customers and other stakeholders are increasingly demanding transparency on ESG issues.
Our Excel template guides you step by step through the double materiality assessment and automatically generates your materiality matrix.
2. Determine the relevant data points
Once material topics are identified, the next step is to pinpoint the specific metrics and data needed to report on them. The data points you select should give a clear and measurable picture of your ESG performance. Make sure they align with the ESRS standards and the specific CSRD requirements.
How to determine your ESRS data points
- Start with the EFRAG list of ESRS data points. Use the EFRAG ESRS data points list as your starting point.
- Extend the template with additional columns, for example:
- Material: Is this data point material based on the identified topics?
- Responsibility: Which department or person collects this data point?
- Data availability: Is the information already available, or does a process need to be set up?
- Data source / system: Which system holds the relevant information?
- Comments: Space for notes.
- Determine material data points. For each of the 11 ESRS standards, decide whether a data point must be reported based on your material topics. Certain data points (e.g. ESRS 2 or IRO-1) are mandatory for all companies.
- Complete the additional columns (optional). Fill in the extended table and add any company-specific data points.
- Apply filters. You can filter the list so only reportable data points are shown. Useful filters include:
- Phase-in for companies with fewer than 750 employees
- Phase-in for all companies
- Voluntary data points
- Essential data points only
Note: the revised ESRS draft published by the EU Commission on 6 May 2026 proposes cutting mandatory data points by over 60%. The simplified requirements are not yet final, but if adopted they will significantly reduce the data collection burden.
Mapping material topics to data points is still time-consuming. CSR Tools supports customers in this step and has extended the EFRAG template with helpful macros. You can also use the ESRS data points mapping tool to find your material data points in seconds rather than reviewing each one manually.
Need support? Contact us anytime.
3. Gap analysis and data collection
The third step is a gap analysis followed by data collection. The gap analysis tells you what data you already have and what still needs to be gathered to cover the requirements that emerged from your materiality assessment.
The additional columns "Responsibility", "Data availability" and "Data source / system" from the previous step give you a quick overview of which data is missing, who owns it, and where existing data lives.
Once gaps are identified, you collect the data needed to paint a comprehensive picture of your ESG performance. This requires a systematic approach to ensure the data you collect is reliable, accurate and representative. You may need to implement new methods or adapt existing processes to collect and process the required information effectively.
4. Prepare the report
With data collected, step four is report preparation. In this phase, you structure and format the data in a way that meets CSRD requirements. From 2026, the report must be provided digitally and machine-readable, with information marked up using the XBRL standard (ESEF format).
Your sustainability report should include both quantitative data and qualitative explanations of the key topics. Aim for a report that is clear, coherent and understandable for all stakeholders. This means presenting complex information accessibly while covering all relevant ESG topics in sufficient depth. Make the methodology of data collection and processing transparent to build credibility and trust.
If you are reporting voluntarily using the VS (Voluntary Standard, based on VSME), this Word template gives you a ready-to-use report structure.
5. Review and audit
The review and audit phase is critical for credibility. Your report goes through a thorough internal review, then an external audit by an independent third party.
The CSRD requires the sustainability report to be audited by a certified auditor. Initially, limited assurance is sufficient. The expectation is that the standard will be raised to reasonable assurance (on par with the financial audit) in future.
These audits confirm compliance with legal requirements and industry best practices, and flag any inaccuracies or omissions. Give auditors access to all necessary information and documentation. Clean, consistent documentation throughout the entire process pays off here.
The audit outcome should also inform continuous improvement of your internal processes. Successful completion builds stakeholder confidence in your ESG reporting and strengthens your company's reputation for transparency.
6. Finalize and publish
After the report is validated through reviews and audits, make any final adjustments to ensure all information is accurate and complete. This step includes final approval by management and the supervisory board. Both bodies should already be regularly involved throughout the process.
Publication should be planned to achieve maximum reach and impact. Choose platforms and formats that comply with legal requirements and reach your target audiences effectively. Many companies use both digital and traditional channels to disseminate their CSRD reports and integrate them into their overall communication strategy. Publishing transparently strengthens stakeholder trust and positions your company as a responsible actor.
Does ESG software make sense for CSRD reporting?
Six steps to a finished CSRD report? In theory, yes. In practice, each step involves significant effort. Specialized ESG software can make a decisive difference. These solutions are designed to simplify and optimize the creation, management and submission of ESG reports. Our ESG software overview covers the most relevant tools for CSRD reporting.
Here is where ESG software creates real value at each step:
1. Materiality assessment
The Excel template from CSR Tools guides you step by step through the double materiality assessment. Some providers (e.g. Luup) specialize in materiality assessment. All-in-one ESG software solutions can assess both impact and financial materiality and automatically collect stakeholder feedback.
2. Data point determination
ESG software helps you identify and categorize relevant data points precisely. It enables systematic collection and management, which is particularly useful for compliance with the detailed CSRD requirements. Integrated reporting standards ensure all relevant aspects are covered. The ESRS data points mapping tool identifies your material data points at the touch of a button.
3. Data collection
Data collection is where ESG software delivers perhaps the greatest advantage. It can automatically aggregate data from various internal and external sources into a central system. This simplifies the process considerably and improves data quality by reducing manual transmission errors.
4. Report preparation
ESG software compiles collected data into a formatted, CSRD-compliant document, including XBRL tagging. Automated templates and report structures make it easier to produce compliant reports. Visual data presentations improve readability and interpretation.
5. Review and audit
ESG software supports the review and audit processes by providing comprehensive audit trails that document every data entry and change. This makes data fully traceable and verifiable for internal and external auditors.
6. Finalization and publication
Many solutions support the final review and approval workflows. Some allow reports to be published directly on company websites or shared via other channels, speeding up the dissemination process.
Selecting CSRD reporting software
Studies by PwC and Ubirch show that the market is highly fragmented, which makes tool selection difficult. The CSRD Software Selection Guide provides a structured approach and the software evaluation model gives you a concrete methodology. We at CSR Tools are also happy to advise you on tool selection.
In summary, ESG software offers significant benefits at every step of the CSRD reporting process: from increased efficiency and quality assurance to compliance and audit readiness. By integrating the right software, you can save time and resources while ensuring your reporting meets the latest standards and is valued by your stakeholders.
Start with the foundation. Our Excel-based double materiality assessment template guides you through the process step by step and generates your materiality matrix automatically.
Frequently asked questions about CSRD reporting
Who is still required to report under CSRD after the Omnibus changes?
Since 18 March 2026, CSRD reporting is mandatory only for companies with more than 1,000 employees AND more than €450m net turnover. Both criteria must be met. The previous thresholds (250 employees, "2 of 3 criteria") no longer apply. Companies outside this scope may still report voluntarily using the VS (Voluntary Standard, based on VSME).
Where do I start with CSRD reporting?
Start with the double materiality assessment. This identifies which sustainability topics are material for your company, and everything else in the reporting process follows from it. Use a structured template or software tool to guide you through the stakeholder engagement and scoring process.
How many ESRS data points do I actually need to report?
The number depends on your material topics. The EFRAG list includes over 1,100 data points, but many are voluntary or subject to phase-in rules. The revised ESRS draft from May 2026 proposes cutting mandatory data points by over 60%, which would significantly reduce the reporting burden. Until those changes are finalized, work from the current ESRS standards and filter to your material topics.
Does ESG software pay off for smaller CSRD projects?
It depends on the scope. For companies doing the full CSRD process, ESG software saves substantial time on data collection, data point mapping and report generation. For voluntary reporting using the VS standard, a well-structured Excel template combined with a Word report template may be sufficient. The key is to choose a tool that matches your actual reporting scope.
