Based on our work with Wave 2 companies, we consistently see the same five areas where preparation is most underestimated.

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1. Double materiality analysis (DMA)

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The DMA is the backbone of your entire CSRD preparation. It determines which topics you report on – and therefore also which data you need to collect, which systems you need and what your governance will look like. Starting the DMA too late puts pressure on the entire process.

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What a good DMA requires, how to use it strategically and why the revised ESRS standards enable a more pragmatic approach: you can read all about this in our article on double materiality analysis.

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→ Read: Double materiality analysis: from check-box to strategic compass

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2. Data management

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ESRS-compliant data is rarely ready-made in existing systems. Whereas financial reporting relies on consolidated figures from a single system, CSRD reporting requires data from HR, operations, finance, procurement and the supply chain – in a quality that is traceable and reproducible for an external auditor.

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Most organisations underestimate what this means operationally: which systems need to be adapted, who supplies which data, via which process and at what frequency? Data architecture is not an IT issue. It is a strategic issue that needs to be addressed in good time.

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3. Governance

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CSRD reporting without clear ownership will stall. In practice, we see sustainability teams focusing on content, but lacking formal governance and involvement from senior management and the board of directors – even though this is mandatory for the assurance phase.

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What is needed: an appointed owner or steering group for the CSRD process, internal control mechanisms, formal approval processes and effective collaboration between sustainability, finance, HR and operations. You cannot build this in a matter of weeks.

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4. Reporting processes

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You don't write a CSRD report in the last few months of the financial year. Data collection, internal review rounds and assurance preparation run throughout the year. Without a structured annual calendar – with clear deadlines per department and per ESRS theme – delays will pile up.

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Use the test years 2025 and 2026 to calibrate those processes. Mistakes in a dry run are instructive; mistakes in the first official report are costly.

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5. EU taxonomy

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For organisations with relevant economic activities, the EU taxonomy is an additional obligation that is separate from ESRS reporting but is published alongside it. An eligible/aligned assessment, technical screening criteria (TSC) and the DNSH test require specific expertise and preparation. Those who only discover the taxonomy at the time of the final report will face a catch-up process that could have been avoided.

In our projects, we see a number of patterns that recur in organisations that start too late or underestimate the complexity.

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Mistake 1: postponing governance until the data is available

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Many organisations want to know what needs to be reported before they think about who is responsible for what. But governance is a prerequisite for good data, not the other way around. Without formal ownership and internal control mechanisms, data collection produces unreliable results – and you only notice this when the auditor is already at the door.

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Mistake 2: treating data management as an IT project

ESRS data is not a printout from an existing ERP system. It requires coordination between departments, new measurement processes and a quality framework that is audit-proof. Organisations that delegate data management to IT without strategic guidance from finance or sustainability build data architecture that does not meet ESRS standards.

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Mistake 3: Treating assurance as the final step

Limited assurance is not a final check that you schedule once the report is ready. It is a quality test of your entire reporting process – from DMA to data to governance. Those who only start thinking about audit compliance in the final months run the risk of deviations or delayed publication.

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Those who do not take advantage of the test years 2025 and 2026 will lose irreplaceable time. The quality of your first report is determined long before the reporting year begins.