On 3 June, the public consultation on the simplified ESRS closed. Now that the ground rules for sustainability reporting under the CSRD are set, the question is this: how do you build a report that works? Among Wave 2 companies – in scope from financial year 2027 – we often hear that compliance and readability are treated as separate goals. “First our report has to meet the auditor’s requirements; the communication can follow later.” That reasoning is understandable, but it leads to duplicated effort and only half the impact. So how should you approach it instead?
The revised European Sustainability Reporting Standards (ESRS) aim for “fair presentation”. In other words: a sustainability report is not a tick box list of data points, but a faithful picture of your organisation’s material impacts, risks and opportunities.
It follows that compliance and readability do not stand apart. A report that meets every technical requirement but tells no coherent story falls short. And a report that reads well but does not adequately substantiate its material choices will not pass assurance either.
So this is not a matter of two consecutive steps, but of two dimensions of the same task.
Limited assurance is not only about data. An auditor assesses the report as a whole, including the narrative disclosures.
This has practical consequences:
• Vague phrasing such as “We aim to”, without a clear description of policies, processes or actions, can lead to audit findings.
• Inconsistencies between text and figures stand out. An ambitious climate section that does not align with the reported E1 figures raises questions.
• Materiality choices must be documented not only in the double materiality assessment (DMA); the report itself must also make clear why particular topics are material.
An auditor who cannot find and follow the common thread of a report will notice. Clarity is not an extra layer on top of compliance, but a quality that directly affects assurance.
The reverse is equally true. Good editing and an attractive layout are not enough to make a CSRD report readable. It starts with choices of substance – the very choices you also need for assurance.
A report that treats every topic in the same way, without clear priorities or connections, makes the underlying materiality analysis hard to recognise. Readers need to understand how the material topics relate to your organisation’s business model and strategy. They need to follow how policies, targets and actions flow from the identified impacts, risks and opportunities. And figures only take on meaning for them once you place them in context.
These are the very features an auditor looks for: coherence, consistency and traceability.
A readable, audit-ready report needs a clear common thread, and that thread comes from your organisation’s sustainability narrative. It makes clear why topics are material, what choices you make and how sustainability is woven into your strategy.
The narrative looks different for every organisation. A manufacturer investing in more efficient processes tells a different story from a service provider whose impact comes primarily from client relationships. That distinctiveness is what makes a report authentic and recognisable.
That is also why a strong narrative does not emerge in the final phase of the reporting process. It is set early, on the basis of the DMA results, and then tested through the year against new developments, data and revised choices.
Most organisations still work in two steps. First they get their data, processes and governance in order. Only then do they think about the story their report tells. If you regard these as separate goals, that sequence makes sense.
But once you recognise that readability and audit-readiness require the same discipline, you can no longer separate both steps.
In practice, this means:
• Defining the report’s narrative structure before the drafting phase, taking the DMA as your starting point.
• Describing policies, targets and actions in a specific, consistent and verifiable way, without losing sight of readability.
• Presenting data not as isolated KPIs, but embedded in the story they support.
• Identifying inconsistencies between ambitions, policies and reported results before assurance begins.
This approach calls for alignment between the sustainability, finance and communications teams, as well as clear ownership of the report as a whole. Only then can you arrive at a deliberately built picture of the organisation – rather than a document that has grown out of a spreadsheet.
A CSRD report that is both compliant and readable does not come together in the final sprint of the financial year. You build it step by step – and you can start today.
Since 3 June, the uncertainty around the ESRS is over. Wave 2 companies now know the framework within which they will report from financial year 2027. And that year is approaching fast: the building blocks need to be in place by the end of 2026.
Organisations that want to carry out a full measurement of their first CSRD year would do well not to wait for official publication in the Belgian Official Gazette – by then it would be too late. Decide now what kind of report you want to build. And lay the foundations.
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