The Corporate Sustainability Reporting Directive (CSRD) — effective for large EU companies from 2024 and tech companies with EU operations from 2025 — is the most comprehensive ESG reporting mandate in history, requiring detailed, audited disclosure of environmental, social, and governance data according to European Sustainability Reporting Standards (ESRS). For technology companies in scope, CSRD is not a communications exercise — it is a data management and governance challenge requiring new measurement systems, audit trails, and executive accountability structures. This guide covers what tech companies must report and how to build the infrastructure to do it.
CSRD Scope: Are You In?
Key ESRS Requirements for Technology Companies
| ESRS Standard | What Tech Companies Must Report | Data Challenge |
|---|---|---|
| ESRS E1 (Climate) | Scope 1, 2, and 3 GHG emissions; net-zero transition plan; physical/transition climate risks | Scope 3 upstream/downstream emissions — suppliers, customer product use |
| ESRS E2 (Pollution) | Data centre water usage (WUE); e-waste and hardware disposal | WUE measurement across co-location providers |
| ESRS S1 (Workforce) | Gender pay gap; diversity data; collective bargaining; working conditions including contractor workforce | Contingent workforce data collection |
| ESRS G1 (Governance) | Anti-bribery; tax transparency; political engagement; whistleblower policies | Third-party due diligence documentation |
| ESRS S4 (Consumers) | Data privacy practices; product safety; AI and algorithmic impact | AI impact assessment documentation requirement |
Start with the double materiality assessment (DMA) — CSRD's required process for identifying which sustainability topics are material to your company. Engage a sustainability consultancy for the DMA: interviews with stakeholders, impact identification across your value chain, financial materiality scoring. The DMA output determines which ESRS disclosures are required vs voluntary. Simultaneously, establish data collection baselines for Scope 1 and 2 GHG, energy consumption, headcount by demographics, and data centre PUE/WUE. Connect to your data analytics platform for ESG data management.
Scope 3 is the hardest challenge — start collecting data for your most material categories. For tech companies: Category 1 (purchased goods/services — hardware, cloud), Category 6 (business travel), Category 8 (upstream leased assets — cloud compute), and Category 11 (use of sold products). Request Scope 1+2 data from your top 20 suppliers as part of vendor questionnaire. Run ESRS gap analysis against your current disclosures — identify reporting gaps that require new data collection. Engage an assurance provider early to understand their data quality requirements.
Our data analytics, DevOps, and digital transformation teams help technology companies build the data infrastructure required for CSRD compliance. Book a free advisory session.
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