CSRD First Report Checklist

Pre-filing checklist — content and data

Double materiality assessment: documented, board-approved, stakeholder-engaged, with explicit rationale for all included and excluded topics. Check that excluded topics have brief written explanations in the report.

ESRS 2 disclosures: GOV-1 through GOV-5 complete; SBM-1 (business model), SBM-2 (stakeholders), SBM-3 (material IROs) complete; IRO-1 (risk identification process) and BP-1/BP-2 (basis for preparation) complete. ESRS 2 is mandatory in full — no omissions without explicit transitional relief documentation.

Topical ESRS disclosures: For each material topic — complete disclosure of all mandatory datapoints under Amended ESRS (for Wave 2) or original ESRS (for Wave 1). Check against the EFRAG mandatory datapoint list for each standard. Document any datapoints omitted under transitional relief provisions with the specific provision cited.

EU Taxonomy KPIs: Revenue, CapEx, and OpEx eligibility and alignment percentages for all six environmental objectives. Taxonomy tables completed in EFRAG-prescribed format. Consistency check between Taxonomy revenue figures and financial statement revenue.

GHG emissions: Scope 1, 2 (location and market-based), and Scope 3 by category disclosed. Methodology note documenting emission factors, GWP basis (IPCC AR6), and calculation approach. Percentage of Scope 3 calculated using primary vs secondary data disclosed.

Consistency check: Cross-reference sustainability report against financial statements — climate risk provisions, environmental liabilities, transition CapEx in financial statements must be consistent with E1-9 and E1-3 disclosures.

Pre-filing checklist — process and assurance

Assurance opinion: Limited assurance opinion received from accredited provider covering the full sustainability report including XBRL tags. Opinion must be unqualified (or any qualifications must be disclosed and understood). Assurance provider independence confirmed — no conflicts with advisory services provided.

Board/management sign-off: Formal approval of the sustainability report at board or appropriate governance level. Board minutes documenting approval of the report — this is both a regulatory requirement and an assurance evidence item. Responsibility statement from management included in the report.

Stakeholder engagement documentation: Evidence of stakeholder engagement inputs to materiality assessment available for regulatory review. Engagement activities, participants, outputs, and how they influenced materiality conclusions documented and retained (not necessarily published but available).

Internal review: Senior management review of the full report — not just the summary. Finance director or CFO review of Taxonomy KPIs for consistency with financial statements. Legal review of any liability-sensitive disclosures (G1-4 corruption incidents, S2 human rights incidents, E2-6 remediation liabilities).

Data quality review: Spot-check 10–15 quantitative datapoints by tracing from reported figure back to source data. Verify emission factor versions are correct for the reporting year. Verify headcount figures are consistent between different ESRS sections. Check for arithmetic errors in percentage calculations.

Pre-filing checklist — technical and filing

XBRL validation: Run the ESRS XBRL Taxonomy validation tool against your tagged report before submission. Zero validation errors required — any validation failures will cause ESAP rejection. Common errors: missing mandatory tags, incorrect element selection, unit formatting errors, duplicate tag IDs.

ESAP filing registration: Confirm your company is registered on ESAP and your filing credentials are active. First-time filers must register before filing — allow 5–10 business days for registration processing. Test the ESAP filing interface before the deadline.

Document format: Report must be in iXBRL format — HTML with embedded XBRL tags. Confirm your ESG platform or XBRL tool outputs valid iXBRL. Standard HTML or PDF reports are not acceptable for ESAP filing even if they contain correct content.

National filing requirements: Some member states require filing in the national business register in addition to ESAP — check national requirements in each jurisdiction where you have filing obligations. Germany (Bundesanzeiger), France (Infogreffe), and other member states have specific national filing procedures.

File 2–4 weeks early: Build a buffer before the regulatory deadline. ESAP technical issues, last-minute assurance queries, and XBRL validation failures need resolution time. A company that files 2 weeks before the deadline has time to correct errors without regulatory breach.

Post-filing: Retain all source data, calculation workbooks, and assurance working papers for at least 5 years — the statute of limitations for regulatory review and civil liability claims. Establish a version control system for the filed report in case restatement is required.

Frequently asked questions