
CSRD reporting covers the energy part of a sustainability report: consumption, emissions and the source data behind them, in a form an auditor can follow. Since the Omnibus revision of February 2026, the direct obligation applies only to companies above 1,000 employees and EUR 450 million turnover, from financial years starting in 2027. Companies below that threshold are reached through the value chain instead, when a reporting customer asks them for the same figures.
The energy section of a sustainability report is only as strong as the trail behind each number. Below is that trail, and the document each step leaves behind.
Picture an energy section built from last year's spreadsheet, updated with a rough estimate for what changed. It reads fine until someone asks where one of the numbers actually came from, and the answer has to be a document rather than a recollection.
Source records
Meter readings, supplier invoices and fuel deliveries, per site, for the reporting year.
Proved byMetering data, invoices, delivery notesAllocated by scope
Own combustion, purchased energy and the chain kept apart, against a written organisational boundary.
Proved byConsolidation sheet and boundary noteMethod and factors
Which emission factors, which version, and which scope 2 method: market-based, location-based, or both.
Proved byMethodological note, versioned and datedThe disclosed figure
What appears in the climate section of the report, still connected to every step behind it.
Proved byThe report, plus the trail back to the source recordsThe chain breaks at the estimate. A site with no metering data for part of the year gets filled in, and that fill-in is what someone will ask about. Finding those sites before the report is written is the difference between a correction and a question you cannot answer.
Scope 2 depends on which method you state.
The same consumption yields a different figure market-based than location-based, because the first counts your guarantees of origin and the second counts the grid you drew from. Saying which one you used is part of the disclosure.
The method note is the part people skip.
Emission factors are revised. Without a dated note saying which version was applied, this year's figure cannot be compared with last year's, and neither can be re-derived.
You may be asked without being in scope.
Since the Omnibus revision of February 2026, the direct duty starts above 1,000 employees and EUR 450 million turnover, from financial years starting in 2027. Below that the request still arrives: a supplier to a reporting company gets asked regardless of its own obligation.
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