CSRD reporting rarely fails because of lack of will. It almost always fails for the same three reasons: nobody knows exactly which department must deliver which data, there is no consistent collection process, and the numbers do not match at the end.
This article shows how companies structure CSRD data processes across departments, which ESRS standards affect which internal functions, and how Dcycle automates coordination.
Why CSRD is a cross-department coordination problem
CSRD and its European Sustainability Reporting Standards (ESRS) require disclosures on environmental, social and governance topics. What looks like a sustainability topic on paper is in practice a company-wide data project.
Scope 1 and Scope 2 emissions come from production and facility management. Scope 3 emissions in the supply chain are owned by procurement. HR delivers workforce metrics. Governance disclosures come from legal or directly from the board. Financial metrics for EU Taxonomy or ESG-linked finance come from controlling.
No single function owns all the data. Without clear responsibilities and a central system, the typical chaos emerges: scattered Excel files, inconsistent units, missing source references and missed deadlines.
Practical tip: Start CSRD preparation with an internal data stakeholder map: which department owns which data? This overview, created before the first data entry, prevents weeks of rework later.
ESRS standards and internal ownership
ESRS are grouped into five areas: Environment (E), Social (S), Governance (G) and cross-cutting standards (ESRS 1 and ESRS 2). Each standard has direct impact on specific business functions.
ESRS E1: Climate change
The central ESRS for most companies requires complete Scope 1, Scope 2 and Scope 3 emissions inventories, climate risk assessments and a transition plan.
Lead departments: Facility management and production for Scope 1 (direct emissions) and Scope 2 (electricity and district heating). Procurement for Scope 3 categories such as purchased goods and services, business travel and logistics. Controlling for financial climate risks.
Particular challenge: Scope 3 emissions require supplier data. Without structured supplier surveys, Category 1 (purchased goods) remains a rough estimate. Dcycle simplifies this through automated supplier questionnaires.
ESRS S1: Own workforce
ESRS S1 requires detailed workforce disclosures: employment relationships, diversity, pay, training, occupational health and safety and trade union representation.
Lead department: HR. In practice, SMEs and mid-sized companies often lack standardised HR systems that deliver these metrics consistently. Training hours, turnover rates and pay transparency disclosures are frequently not captured systematically.
Lead department (occupational safety): EHS (Environment, Health and Safety) or safety officers where they exist. In smaller companies, often production management.
ESRS G1: Business conduct
ESRS G1 covers anti-corruption, lobbying, tax governance and supplier management.
Lead department: Legal or compliance, or the board directly where there is no dedicated legal function. Specific datapoints include confirmed corruption cases and how they were handled, lobbying spend and complaint mechanisms.
ESRS E2–E5: further environmental topics
Water use (E3), biodiversity (E4) and resource use/circular economy (E5) mainly affect manufacturing companies and are owned by production, facility management and procurement.
Focus on materiality: Not all ESRS apply to every company. The double materiality assessment determines which topics are in scope and which can be omitted. That reduces collection effort significantly.
The most common data gaps in CSRD practice
From implementation projects with companies of all sizes, Dcycle sees the same typical problems:
Scope 3 emissions are almost always missing. Most companies can collect Scope 1 and 2 relatively quickly. For Scope 3, supplier data is missing. Categories 1 (purchased goods and services) and 11 (use of sold products) cannot be filled without supplier surveys or lifecycle data.
HR data is unsystematic. Training hours, turnover by gender, pay gaps: many companies do not capture these metrics at all or capture them inconsistently. ESRS S1 effort surprises many companies because it goes far beyond what annual accounts already disclose.
Governance disclosures are poorly structured. Anti-corruption policies exist but are not documented or prepared for ESRS G1. Complaint mechanisms exist but are not formalised enough for audit-ready reporting.
Financial metrics are missing for EU Taxonomy. Companies that must address EU Taxonomy alongside CSRD need CapEx and OpEx breakdowns by sustainable activities. That requires close collaboration between controlling and the ESG lead.
Dcycle shows you in a guided gap analysis which ESRS datapoints are missing in your company and assigns collection directly to the responsible departments.
Start gap analysis →How Dcycle automates cross-department data collection
Dcycle is a data platform built to solve exactly this coordination problem.
Task-based data collection: Dcycle assigns each ESRS datapoint directly to the responsible person. HR sees its tasks, production its energy data, procurement its Scope 3 requirements. Everyone works in the same platform, without email coordination and without version conflicts.
Automated supplier surveys: For Scope 3 emissions and supply chain data, Dcycle sends structured surveys directly to suppliers. Responses flow automatically into emissions calculation.
Real-time gap analysis: At any time you can see which datapoints are still missing, which departments are behind and how complete the current reporting status is. That avoids surprises close to the submission deadline.
Audit trail and versioning: Every data entry is documented: who entered what, when and on what basis. That is the foundation for external assurance, which becomes mandatory for many companies from the second reporting year.
Multi-framework in one platform: CSRD/ESRS, EU Taxonomy, GHG Protocol, LkSG and VSME in parallel in Dcycle. A group subject to CSRD that also needs supplier data for VSME manages everything without redundant data entry.
What a structured CSRD process looks like in practice
A realistic timeline for the first CSRD report in a mid-sized company:
Months 1–2: Complete materiality assessment. Clarify which ESRS topics are in scope. The result determines the entire collection effort.
Months 3–5: Build data processes. Name department owners, assign datapoints, start the first collection round. This phase reveals the actual data gaps.
Months 6–9: Close data gaps. Launch supplier surveys, supplement missing HR systems, formalise governance documentation.
Months 10–12: Draft the report, review internally, involve the auditor. Approve the final report.
Companies running this process without digital support typically report 1.5 to 2 times longer cycle times and significantly higher correction effort before assurance.
Ready to set up your CSRD data collection in a structured way? Dcycle gives you a concrete overview of your starting point in 30 minutes.
Book a demo →Frequently asked questions on CSRD data collection
Who is responsible for CSRD data collection in the company?
There is no single answer. In practice, a central team or a person from controlling or compliance usually coordinates CSRD responsibility. Actual data delivery is spread across HR, production, procurement, facility management and legal. What matters is that the coordinating role has direct access to the board and authority to work across departments. Dcycle supports this model through role-based access and task assignment.
Do we have to report all ESRS standards or only material ones?
Only material ones. The double materiality assessment determines which ESRS topics are in scope for your company. A services company without production sites will typically not need to report on ESRS E2 (pollution). A manufacturing company will rarely avoid ESRS E1. The first step is always materiality assessment, then the collection plan.
What if suppliers do not provide Scope 3 data?
That is a common problem. ESRS allow secondary emission factors (sector averages, GHG Protocol databases) in justified cases when primary supplier data is unavailable. That must be disclosed and explained in the report. Dcycle supports both paths: automated supplier surveys for primary data and integrated emission factor databases for secondary data. Long term, primary data should be the goal, as auditors and investors prefer it.
From when is external assurance of the CSRD report mandatory?
CSRD provides for a phased introduction of external assurance. In the first phase (from 2025, for reports from FY2024), limited assurance applies, comparable to a review. Full assurance (reasonable assurance) is planned for later phases; the exact timeline is still being finalised. Regardless, auditors already expect complete audit trails, source references and documented methodology today. Without that, you risk costly rework close to assurance.
How does Dcycle help with the first CSRD assurance?
Dcycle documents every datapoint with entry date, responsible person, source and calculation method. This information is available to the auditor at any time, without manual assembly. In addition, Dcycle automatically shows before assurance which datapoints are not yet fully evidenced, so gaps can be closed before the auditor finds them.
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