Since January 2024, any European group that exceeds two of the three thresholds (250 employees, €25 million in total assets, or €50 million in revenue) falls within the scope of the Corporate Sustainability Reporting Directive (CSRD) (EU Directive 2022/2464, Art. 19a); the first reports aligned with the European Sustainability Reporting Standards (ESRS) will be published from fiscal year 2025 for companies already subject to the NFRD, then in 2026 for the others.
By 2028, a non-financial performance statement will also be required from listed SMEs, reflecting a European policy ambition to extend transparency across the entire value chain.
At the same time, the European Central Bank is “greening” its bond purchases, favoring issuers with lower carbon intensity (ECB – Press release of 4 July 2022). Non-financial reporting therefore becomes a pillar of financial strategy rather than a mere appendix.
At company level, CSR governance and social-performance reporting formalize the materiality of environmental and non-financial issues. Their impact extends across society and responds to the European directive, which requires fully sustainable balance-sheet and risk monitoring.
Understanding CSR and its strategic impact
From philanthropy to durable value creation
In ten years, CSR has shifted from an annex to a competitiveness lever:
- Climate performance: 70% of major European funds now apply a differential cost of capital between “green” and “brown” issuers (PwC ESG Global Investor Survey 2024).
- Social compliance: since the Sapin II law, ethical non-compliance can result in penalties of up to 5% of global revenue.
- Operational resilience: the NGFS ranks climate change among the “systemic risks” likely to disrupt supply chains and financial and economic stability (NGFS 2023).
The CFO’s pivotal role
The CFO’s primary responsibility is to secure sustainability data: all non-financial and environmental flows from the ERP, HSE applications, or sensors must feed into a single repository, ready for limited assurance planned for 2027. Issuers already disclosing audited indicators benefit from a bond-spread reduction of around ten basis points (ICMA, Sustainable Bond Market Report 2024).
The CFO also arbitrates investments: incorporating an internal carbon price of €130/t of CO₂ by 2030, as suggested by the IEA Net Zero roadmap (IEA Net Zero Roadmap 2023 scenario), quickly reveals projects with the highest “carbon profitability.” Finally, by merging financial and sustainability indicators in the executive committee dashboard, the CFO significantly shortens the budget cycle and improves performance.
Such commitment gives the non-financial approach an operational dimension: it drives the development of new business lines while enhancing the company’s credibility with investors.
Sustainable transformation: the digital parallel
Like the digital wave of the 2010s, the environmental transition relies on a multi-year roadmap (2030 vision), quick wins (energy OPEX reduction), a dedicated Data Hub, and extensive training of management-control teams in the new standards.
Our advice — Ginesis
As early as 2024, overlay your IFRS risk map with the double-materiality matrix: you will gain one fiscal year in preparing for limited assurance and negotiating future sustainability-linked credit lines.
Any company that integrates CSR into its reporting strengthens its social capital, because the materiality of environmental and non-financial information demonstrates true performance and positive societal impact in line with the European directive, and is reflected both in the balance sheet and in long-term, sustainable risk management.
Non-financial reporting: state of play in 2025
CSRD / ESRS: expanded scope and mandatory assurance
Since 1 January 2024, the CSRD applies to any company exceeding two of the three thresholds (250 employees, €25 million in assets, €50 million in revenue), i.e., ≈ 50,000 groups in the EU versus 11,600 under the NFRD. It requires:
- XBRL format for each data point, interoperable with ISSB/SASB; untagged reports will be deemed incomplete.
- Double materiality: analyze both outside-in (financial risk) and inside-out (societal impact).
- Limited assurance by the statutory auditor from fiscal year 2027, raised to reasonable assurance by 2029 (CSRD FAQ 2024).
In practice, the number of audited indicators rises from 40 (DPEF) to 200–250 (ESRS E1–E5, S1–S4, G1). Early feedback shows that a CAC 40 group already devotes 1,500 person-days of internal teams to tagging its data.
Our advice — Ginesis
Quickly map your priority ESRS gaps: climate (E1), workers (S1), and governance (G1). Assign one data owner, one internal controller, and one auditor per KPI to avoid orphan areas and secure limited assurance.
Double materiality: step-by-step method
- List ≈ 120 ESG topics via press reviews, sector analyses, and stakeholder expectations.
- Score each topic from 1 to 5 on two axes—financial impact and societal impact (PwC 2024 method).
- Prioritize the 4–5 / 4–5 cells: these become reportable KPIs with quantified targets and an action plan.
- Document the matrix in an annexed Policy Paper (requirement ESRS 2.MR).
This matrix is not a theoretical exercise; it forms the basis of the Policy Paper required by ESRS 2.MR and will be reviewed during limited assurance from 2027. Above all, it embodies the “scale shift”: the company and its environment now operate on comparable orders of magnitude; ignoring water risk or carbon pressure exposes up to 5% of EBIT by 2030 (NGFS, 2023). For a methodological deep dive, see our article on double materiality.
Grey areas and market convergences
- Headcount: the CSRD recommends FTE but tolerates head-count if explained (EFRAG guide 04-2025).
- Avoided emissions: may be disclosed but are excluded from carbon intensity; only actual emissions feed E1 KPIs.
- Scope 3: exclusions are possible (e.g., category 15—investments) provided a coverage timetable is presented—AFEP-MEDEF discussion, March 2025.
- Sensitive data: the standard allows aggregation (>75% of the total) to protect competitiveness, provided the methodology is transparent.
Stakeholder expectations: what is at risk?
| Stakeholders | Priority requirement | Consequence of weak reporting |
| Investors | Comparable & audited data | Financing premium |
| B2B customers | Scope 3 traceability | Loss of tenders |
| Talent | Tangible values | High turnover |
| Regulators | Consistency of narrative / XBRL | Sanctions and penalties |
Thus, the cost of undersized reporting is reflected in a lower valuation and a higher cost of capital; conversely, reliable reporting paves the way for Sustainability-Linked Instruments and EIB financing.
The strategy of the modern enterprise combines CSR governance, continuous reporting, social progress, and the materiality of each non-financial line item with environmental issues—transforming internal performance into external societal impact as required by the European directive—while aligning the balance sheet with a truly sustainable risk map.
Implementing robust non-financial reporting
Data governance and architecture
The foundation of economically credible CSRD reporting starts with an exhaustive inventory of sources: each flow—whether from finance ERP, HSE, the energy system, HR databases, or IoT sensors—receives a unique metadata sheet (scope, frequency, unit). This mapping prevents the emergence of “shadow KPIs” and feeds a central repository that serves as the auditors’ entry point; it meets the traceability requirement set by ESRS 2 “Data Governance” and prepares for limited assurance from 2027.
Once sources are identified, data lineage traces each field from creation to XBRL publication, providing the transparency required by statutory auditors. SOX-style controls complete the framework: preventive workflows (hierarchical validation, reasonableness thresholds) and detective RPA scripts that flag duplicates, outliers, or missing fields in real time. Groups that have industrialized these controls reduce climate-indicator error rates below 2%—a threshold considered “investment-grade” by agencies (source: PwC ESG Data Survey 2024)—and clear the audit stage much faster.
Collection & automation of flows
Reliable ESG collection starts in the field: IoT sensors and an Energy Management System continuously feed Scopes 1–2, while an ETL pushes data into a secure ESG Data Hub. Each record receives a timestamp and immutable version number, a sine qua non for future ESRS limited assurance. Downstream, RPA bots apply pre-configured controls—reasonableness thresholds, empty-field detection, anomaly scoring—before storing evidence files in ISAE 3000 (rev.) format.
Digitalization and artificial intelligence
Digitalization then acts as a lever: hybrid machine-learning models coupled with local weather data improve Scope 2 forecasting by ±2% over 18 months, helping to secure KPI clauses in a Sustainability-Linked Bond. In parallel, natural language processing (NLP) automatically extracts CSR clauses in 97% of supplier contracts, facilitating ESRS S2 compliance and freeing several hundred legal hours. Finally, an anomaly-scoring module flags abnormal energy invoices in real time (>3σ), avoiding on average €1.2 million in re-billings per year across a multi-site perimeter. The result: data that are scalable, audit-ready, and immediately actionable for the finance function.
KPI methodology & granularity
| Phase | Average timeline | Key deliverable | Success KPI |
| Materiality kick-off | 4 wks | Two-axis matrix | Issues scored |
| KPI design | 6 wks | Single glossary | 1 definition / KPI |
| Collection pilot | 3 mos | “Sprint” dashboard | Complete data |
| Audit break | 1 mo | Assurance files | 0 major findings |
Preparing for the 2027 audit: the ISAE 3000 checklist
- Design tests: verify that a control exists for each major risk.
- Effectiveness tests: random sampling of the 25 critical KPIs, error threshold ≤5%.
- Sample validation: third-party reconciliations (e.g., electricity invoice vs. IoT sensor).
- Representation letter: sign ESRS + XBRL conformity before external review.
When a company structures its CSR management and integrated reporting, it links social value and the materiality of each non-financial item to environmental challenges—transforming internal performance into impact recognized by society and compliant with the European directive—while aligning its balance sheet with a genuinely sustainable risk map.
Our advice — Ginesis
Plan a pre-audit under ISAE 3000 18 months before the CSRD deadline: you can save up to –30% on assurance fees and avoid last-minute revisions.
Strategies to maximize impact
Develop an effective action plan
Reporting is only valuable if it feeds a multi-year action plan that integrates budgets, human resources, and governance. Best practice is to translate each “double-materiality” KPI into CAPEX, OPEX, and annual targets—for example: reduce carbon intensity by –30% over five years (E1 KPIs) or raise the share of taxonomy-aligned revenue to 40%. These targets are included in the Executive Committee dashboard alongside EBITDA and ROCE; finance can thus arbitrate dividends vs. decarbonization investments, measure the effect on the WACC (average green premium of –30 bps, ICMA 2024), and adjust variable remuneration.
A pragmatic sequencing:
- 2024–25: ESRS compliance, creation of an ESG Data Hub, SOX-ESG controls.
- 2025–27: RPA/AI automation, first Sustainability-Linked Bond (SLB), ESG rating “A.”
- 2027–30: Scope 3 extension, reasonable assurance, partial Net Zero trajectory.
Examples of successful implementation
Our experience — Ginesis
- Glass: internal CO₂ valuation at €130/t → €120 million reallocated to electrification, +1.6 pp of ROCE.
- Transport: €300 million sustainability bond with a reduced coupon if the carbon trajectory is met, heavily oversubscribed.
- Universal bank: fusion of climate indicators and market risk, faster limits-committee decisions.
These cases show that well-designed ESG-finance steering frees up capital, reduces risk, and accelerates decision-making.
Protect confidentiality without sacrificing auditability
The CSRD requires granularity but allows aggregation (>75%) to protect strategic data (ESRS G1-17). High-performing groups adopt a three-tier model:
- Open dashboard: around ten key public indicators (CO₂ intensity, share of green CAPEX).
- Analyst data room: full XBRL report, accessible under NDA.
- Internal sanctuary: unit costs and proprietary algorithms, outside the publication scope.
Confidentiality workflows are integrated into the Data Hub; a “sensitive” tag triggers automatic aggregation prior to extraction.
Transparency and communication: building trust
Monetization requires balanced communication that combines progress, limits, and remediation plans; this is the condition for inclusion in major ESG indices and access to green-priced revolving facilities. Top performers publish interactive dashboards (Power BI) updated quarterly, link each KPI to a concrete action, and verify narrative/data consistency (the AMF-recommended “tell-and-show” controls).
Anticipating sustainability-related risks and opportunities
The PNACC 3 estimates the cost of climate inaction at 13% of French GDP by 2050; at the company level, this amounts to –5% of EBIT per year for intensive sectors (NGFS). Integrating a climate stress test (internal CO₂ price €130/t, water +50%) into Value-at-Risk helps negotiate “green” covenants.
Sustainable finance lowers the cost of capital: a Green Schuldschein reduces the spread by about 20 bps; responsible factoring trims 1.5 points from the discount; and a CCUS/hydrogen structure combining an Innovation Fund grant (60% CAPEX) with a 20-year EIB loan cuts the WACC by 80–120 bps. Value creation is evidenced by precise sector indicators (tCO₂/ton, kWh/MWh data center, green-loan ratio) already included in EFRAG’s 2025 sector ESRS.
Ultimately, a company that masters CSR and reporting advances its social capital, formalizes the materiality of its non-financial assets, reduces its environmental footprint, optimizes performance, and measures societal impact in line with the European directive—securing its balance sheet and mitigating each risk in a fully sustainable way.
Non-financial reporting is not a regulatory cost: it becomes the strategic compass that guides capital allocation, secures the value chain, and strengthens the trust of investors, regulators, and employees. CFOs who can ensure data reliability and align investments and remuneration with material KPIs will build the resilient champions of 2030.
Take action with Ginesis: Download our premium guide “CSRD 2025 Roadmap,” or request a strategic non-financial audit to convert your obligations into a driver of sustainable performance.