Multinational Firm Enhances ESG Data Collection and Reporting to Guide Path to Meet CSRD Requirements

As a multinational professional services company based in the U.S., this client, like many we work with, was concerned about meeting the rapidly approaching requirements of the European Union’s  Corporate Sustainability Reporting Directive (CSRD). This regulation requires “all large companies and all listed companies (except listed micro-enterprises) to disclose information on what they see as the risks and opportunities arising from social and environmental issues, and on the impact of their activities on people and the environment.” Disclosure will begin in 2026 using data from FY2025. Overall, the client was seeking to enhance trust and confidence in its ESG data and collection processes. The company’s senior leaders realized they needed a better understanding of the CSRD and how the regulation would impact its global business.

Identifying the gaps

Protiviti was engaged to help the client tackle several ESG data and technology projects. Partnering with the company’s executive team and ESG team, we categorized the challenges into three cross-functional buckets: the ESG reporting process, ESG data and toolsets, and CSRD readiness.

Because ESG initiatives touch so many aspects of the business (there are close to 300 ESG metrics in the client’s annual ESG report), there were hundreds of data owners involved in ESG reporting, from real estate, to operations, legal, HR, finance, and more. Our work included:

• Collaborating with those hundreds of data owners to obtain ESG data and a better understanding of the client’s various ESG-related initiatives, which included:
  • Expanded GHG data collection from facilities and communication with landlords, which allowed the ESG team to identify facilities where renewable energy initiatives can be implemented and/or expanded.
  • Increased collection of actual GHG consumption, revealing insights such as 20%+ reductions in both natural gas and refrigerant emissions.
• Creating a structured quality control review process, using the 200+ ESG metrics from the client’s annual report.
• Mapping steps for analysis of the client’s ESG reporting process.
• Reviewing the client’s existing ESG data management products and services and determining what future investments could be customized to the client’s needs and pricing requirements.  
• Preparing detailed analyses of CSRD/ESRS requirements and evaluating the client’s readiness for compliance with each requirement.
• Conducting a double materiality assessment (DMA) in compliance with European Sustainability Reporting Standards (ESRS) guidance.
• Planning for the implementation of ESG software and standardization of data collection and review processes.
• Educating cross-departmental leadership regarding CSRD legislation and assessing current state readiness for global ESG requirements.

The CSRD reporting pathway clients select now is a critical factor in how their future data collection and reporting platforms will develop. As mentioned, organizations may currently plan to report on an entity, EU consolidated, or enterprise level. However, by 2029, all firms will have to report on the enterprise level using FY2028 data, so if another mechanism is selected now, the company will eventually need to shift. Because of this, many clients, including this one, are electing to begin now with enterprise-level reporting. 

Closing the gaps

As with many clients taking a deep dive into reporting processes and tools, we were able to identify and resolve several gaps for this company.  Specifically, we:

• Developed and implemented an ESG quality control review process, which greatly reduced the number of audit findings from the prior year.
• Increased the collection of actual greenhouse gas consumption data, revealing insights the client had achieved, such as 33% and 20% reductions in natural gas and refrigerant emissions, respectively.
• Progressed executive education and prioritization of a data management tool to support CSRD readiness.
• Provided proposed improvements and efficiencies for the next ESG reporting cycle.
• Capitalized upon the DMA process to increase company-wide ESG knowledge, which enhances the client’s sustainability goals and progress towards those goals.
• Supported a global change management initiative among internal stakeholders to embrace and enhance ESG data collection.

Moving the needle

In addition to the immediate improvements that the client experienced in ESG data collection and reporting, the enhanced processes have led to better decisions regarding their sustainability and environmental programs. As a result, both have contributed to an improved Carbon Disclosure Project (CDP) score from the previous year. The CDP, which provides a snapshot of environmental disclosure and performance, demonstrates the trajectory of an organization’s environmental journey.

We were also able to help the client become more comfortable with its new data collection and reporting tool, and its new workflow processes and assure that its platform now accurately gathers and reflects the work the organization is doing to support global sustainability. This initiative will continue as the client grows and matures its ESG reporting efforts. “Protiviti has been by our side, advocating for our team and helping navigate complex projects, significantly upleveling internal audit results in ESG data, ESG software selection, and EU/CSRD readiness,” said the client’s sponsor. “No matter which MD and team we are working with, we reach our goals together, working to build something better and stronger than where we started.”