For a growing number of businesses in manufacturing, construction and logistics, CSRD reporting is no longer a future concern.
The Omnibus reforms have narrowed who needs to report. But for companies still in scope, the assurance requirement hasn’t gone away. Every CSRD report needs sign-off from an independent assurance provider, working to limited assurance standards. That means your data, your judgement calls and your evidence all need to be up to scratch.
Many businesses often treat the report as the finish line, but the report is just the output. The audit is where the real test happens.
Here are the pitfalls we see most often, and how to steer around them.
Starting the evidence trail too late
The most common mistake is writing the report first and thinking about evidence afterwards. Auditors don’t just want your conclusions. They want to see how you reached them.
That means keeping records as you go.
Save the emails, the spreadsheets, the meeting notes and the source data behind every disclosure. If a figure can’t be traced back to where it came from, it won’t survive an audit.
Building your evidence file alongside your report is one of the easiest ways to keep on top of this.
Treating double materiality as a tick-box exercise
Double materiality is the backbone of CSRD. It asks you to assess both how sustainability issues affect your business, and how your business affects people and the environment.
Auditors will look at this assessment closely, including the topics you rule out. If you decide something isn’t material, you need a documented reason as to why.
A rushed materiality assessment will rarely hold up; it needs clear input from across the business and a clear record of how conclusions were reached.
Leaving sustainability data without a single owner
Sustainability data usually lives in lots of different places across a business. Finance could hold some of it, operations could hold more. HR, procurement and facilities could hold the rest.
Without one person accountable for pulling it together, gaps appear and nobody notices until the auditor does. Every data point in your report needs an owner who can explain where it came from and answer questions about it.
Assign ownership early and make sure that person has the authority to chase data from other teams.
Underestimating supply chain and value chain data
For construction, manufacturing and logistics businesses, a large share of your sustainability impact sits outside your own four walls. It’s in your suppliers, your subcontractors and your materials.
This is usually the hardest data to collect, and the easiest to leave until the last minute. Suppliers don’t always respond quickly, and some won’t have the data in a usable format at all.
Start these requests well ahead of your reporting deadline. Build supplier data collection into contracts and onboarding, so it isn’t a scramble every year.
Businesses are realising how important the right controls are for their sustainability data. You need to know where it comes from, who owns it, and how its accuracy is checked. It’s reportable under CSRD, so now’s the time to get it right. – Emma Gray, Principal ESG Consultant
Assuming limited assurance means light-touch scrutiny
Limited assurance is a lower bar than reasonable assurance, and the Omnibus reforms have confirmed it will stay that way. But limited assurance is still a real audit, with real testing.
Assurance providers will sample your data, question your methodology and check your controls. You’re going to need to report it, so it’s better to get it right before the auditor goes in and takes a look. They’re forming an independent opinion on whether your report is free from material misstatement.
Prepare as though someone outside your business is going to ask the tricky questions.
Disconnecting sustainability reporting from financial reporting
CSRD requires your sustainability information to sit in the same management report as your financial statements, with clear connections between the two. Auditors look for consistency between what your sustainability data says and what your financial data says.
If your carbon figures and your energy invoices don’t line up, or your workforce numbers in the sustainability section don’t match your financial statements, that’s a red flag.
Get your finance and sustainability teams talking to each other early, not just at sign-off.
Bringing your auditor in too late
Some businesses don’t speak to their assurance provider until the report is finished. By then, it’s too late to fix structural problems with how data was collected or documented.
A better approach is to ask your auditor, or an experienced adviser, what they’ll be looking for before you start. Understanding their expectations upfront saves time and avoids nasty surprises close to the deadline.
Going in without a pre-audit checklist
Even businesses that do all the groundwork can still stumble at the finish line, simply because nobody checked everything was actually ready before the audit began.
A pre-audit checklist gives you a way to test your own readiness, before your auditor does it for you. Run through it a few weeks ahead of the audit, so any gaps get fixed on your timeline, not theirs.
Your checklist should cover the basics:
- A signed-off, documented materiality assessment.
- A named owner for every disclosure in the report.
- An evidence file that links back to each figure.
- Supply chain data requests sent, chased and recorded.
- Sustainability and financial figures reconciled against each other.
- Any findings from last year’s audit addressed and closed out.
- Final sign-off from leadership.
A simple shared document that the whole team can check against is often enough. What matters is having one clear, honest view of where you stand before the auditor gets involved.
Getting ready with confidence
A CSRD audit rewards businesses that treat sustainability reporting as a proper business process, with owners, evidence and controls, rather than a document written once a year.
None of this needs to be overwhelming. Getting the groundwork right, materiality, ownership, evidence and supply chain data, makes the audit itself far more straightforward.
If you’d like support getting audit-ready, our team works with businesses across manufacturing, construction and logistics to build CSRD reporting that stands up to the hard questions.
Get in touch to talk through where you are in the process.