CSRD requirements (Corporate Sustainability Reporting Directive) mean that more companies in the EU will be required to report on sustainability in a structured manner. The directive replaces the previous CSR directive with stricter requirements, greater scope, and more uniform reporting across the EU. For Danish companies, this is a matter of compliance, data, and process: What should you report, when, and how do you ensure documentation, quality, and auditor certification? Here you will find an overview of CSRD requirements, ESRS standards, and a practical implementation plan with typical pitfalls and budget items, so you can plan the task as a program—not as a "last-minute report."
CSRD requirements are EU rules for sustainability reporting that oblige companies to report in a more uniform and documentable manner than previously. The requirements are more comprehensive in terms of content, data basis, and internal quality assurance, which must be able to stand up to scrutiny.
The main point: You should not only communicate about sustainability – you must report according to a fixed standard (ESRS) and be able to document data and processes, including double materiality. This requires you to be able to explain your choice of methods, data sources, delimitations, and controls so that reporting is consistent from year to year.
For many companies, CSRD therefore becomes a cross-functional task involving finance, operations, procurement, HR, and management. If you clarify roles early on (who owns which data?), you can typically reduce bottlenecks when the report needs to be compiled, reviewed, and certified.
CSRD requirements cover more types of companies than before. This means that companies that were not previously subject to reporting requirements may become subject to them in the future – and that the reporting task may affect you indirectly through customers, banks, and business partners who request the same type of data.
As a rule of thumb, you should first clarify which business category you fall into and then assess what this means for your internal schedule (data often needs to be collected long before the report is written). Overview of the categories mentioned:
In Denmark, the first reporting period is linked to the 2024 financial year, which will be submitted in 2025. In practice, this means that work on the data basis, governance, and documentation should be operational during the financial year itself—not just at the end of the financial year.
The key dates in the material are:
CSRD requirements must be reported in accordance with ESRS (European Sustainability Reporting Standards). ESRS is the common framework that defines how sustainability data should be collected, structured, and reported so that reporting is comparable and verifiable.
In practice, ESRS helps you answer two management questions: Which topics are relevant (material) to you, and how do you document them with data, methods, and explanations that can be quality assured? This often requires you to establish a fixed cadence for data collection and clear "traceability" from the figures in the report back to the source and responsible function.
The ESRS consists of:
A practical way to get started is to create a simple mapping between the ESRS requirements you expect to report on and the systems/processes where data already exists (finance, HR, procurement, operations). Once you know where the gaps in your data are, you can plan whether to fill them with new measurements, new routines, or system integration.
A key element of CSRD requirements is double materiality assessment. This means that you must assess what is material based on your own finances and operations, and what is material based on your impact on the outside world.
It is important to treat double materiality as a decision-making process, not as a formulation. You should be able to explain who has been involved, what input has been used, and how you have prioritized the topics.
Documentation requirements: The Double Materiality Assessment must be documented. This typically means that you must be able to present a clear method, a decision trail, and a justification for why certain topics are included or excluded. The more consistent the documentation is, the easier the dialogue with the auditor and internal stakeholders will be.
In addition to content, CSRD requirements also impose requirements on form, structure, and quality assurance. This means that the reporting task is not just about "writing a report," but also about being able to deliver it in the correct format and with a verifiable level of control.
Here are the key formal requirements that often affect your planning and resource needs:
For many companies, this becomes a project where governance, control frameworks, and data quality must be upgraded to avoid reporting that cannot be approved. A practical focus point is therefore to agree on internal controls: Who approves figures, how are changes handled, and how do you ensure that the same KPI is not calculated differently in different parts of the organization?
CSRD requirements are often a cross-functional program, not a one-off reporting task. A typical process includes the following steps and timeframes, which you can use to create a realistic project plan with responsible parties and milestones.
When you put the plan into practice, it is valuable to link each step to a specific deliverable (e.g., "approved data collection method" or "first data extract validated") so that you can track progress and reduce the risk of delays.
At the end of the implementation plan, you should ensure that there is a fixed operating model: who updates data, when follow-up takes place, and how changes in methods, supplier data, or internal processes are handled. This makes reporting more robust from the first to subsequent reporting years.
A recurring challenge with CSRD requirements is that it is not enough to have figures: you must also be able to document how the figures have been calculated and how you manage quality and accountability. Certain documents are therefore typically key, because they link the report to your processes and controls.
The following documents are highlighted as critical in working with CSRD requirements:
If you collect these documents as part of your audit trail, it will typically be easier to answer clarifying questions from auditors and internally within the organization. It can also reduce the risk of important decisions being based solely on personal knowledge.
The economics of CSRD requirements depend on complexity, data availability, and system landscape. The estimates below can be used for budget frameworks (subject to variation). To make the figures useful in your own planning, you can link each item to a specific deliverable: e.g., gap analysis, implemented data flow, or prepared certification basis.
The research also indicates that the work can have knock-on effects such as reduced compliance risk and improved investor confidence. Energy optimizations are mentioned as "often valuable," but the effects will vary and must be documented in your own context. A practical approach is therefore to separate "must-haves" (what is required to report and obtain certification) from "nice-to-haves" (measures that can improve data quality, efficiency, or the basis for decision-making over time).
The most typical risks associated with CSRD requirements relate to data, complexity, and communication. Many of these arise when reporting tasks are given low priority initially, or when responsibilities and definitions are not clearly established across the organization.
Here are the most common pitfalls and what they mean in practice:
Practical consequence: It pays to plan data collection and control frameworks early on so that the report can be certified and formulations can be documented. At a minimum, you should ensure common definitions of key measurement points, a clear division of responsibilities for data delivery, and a fixed process for internal validation before the material is sent for external review.
CSRD requirements do not apply to all companies in the same way, and several exceptions and deadlines are mentioned. If you are in or around the SME category, it is particularly important to clarify what is a direct requirement and what may become an indirect requirement from the market (e.g., customers, financing, and supply).
The exceptions and options mentioned are:
If you already do voluntary reporting, it often makes sense to review which parts can be reused as documentation (methods, data sources, governance) – and which parts are typically missing when requirements for standardization, traceability, and certification are imposed.
In Denmark, the Danish Business Authority and FSR Denmark provide guidance to companies on CSRD requirements. At the same time, accounting regulations are updated on an ongoing basis, and the requirements for documentation of double materiality are highlighted as a specific requirement.
For you, this means that it is not enough to "have a story": you must be able to present a coherent basis on which methods, data sources, and decisions can be explained and repeated. A good workflow is to compile internal guidelines for calculation and control, so that you are in a stronger position when the report needs to be quality assured and when follow-up questions arise.
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