What does an ESRS report contain? A reality check from real-world practice

What you can expect from this article

The debate surrounding sustainability reporting remains lively. Politically, not every issue has yet been definitively resolved, but from a technical perspective, preparations have long been underway in many companies. This is precisely where the real challenge lies: those who will be required to report in accordance with the ESRS in future cannot wait until all the details are finalised at the last minute.

Some companies have decided not to wait any longer. They are taking a proactive approach and are already publishing sustainability reports based on the ESRS. What do these reports actually look like? In the live broadcast on 6 May, we took a look at the latest report from Borussia Dortmund football club with Dr Steve Waitschat.

ESRS in Germany: Lots of progress, but not everything has been finalised yet

A key issue is the legal situation in Germany, which remains unclear. The European requirements are in place, but the national implementation has not yet been finalised. For businesses, this means that the general direction is clear, but not every detail has yet been laid down in binding regulations.

At the same time, no one seriously expects the requirements to be drastically tightened overnight. As things stand, the key thresholds remain, in particular, 1,000 employees and a turnover of 450 million euros. For the companies concerned, these are not minor issues, but major corporate projects.

Time pressure is a particularly significant factor. If reporting is required for the 2027 financial year, the relevant data must be collected in 2027 in a manner that is accurate, consistent and audit-proof. It is virtually impossible to set up a robust ESG data system of this scale retrospectively. This is precisely why the current uncertainty surrounding the final standards poses such a challenge for many companies.

Where do companies stand at present?

The situation is mixed. Large companies that have already reported in accordance with the NFRD or have been preparing for several years are often significantly further ahead than others. Many ESG departments are already providing comprehensive key performance indicators and reports of high quality. Yet this is precisely where the next stage of maturity begins.

After all, the real question is not simply: ‘Do we have data?’, but rather: ‘Are we audit-ready?’

In practice, it is evident that the lack of fundamental sustainability information is not the main issue. What is often more critical is whether processes, responsibilities and supporting documentation are structured in such a way as to enable an audit to be carried out efficiently and transparently. Anyone providing figures must also be able to explain:

• Where does the data come from?
• How were they calculated?
• Who is responsible?
• What checks ensure quality and completeness?

It is precisely this transition from high-quality ESG work in terms of content to verifiable ESG reporting that is currently the real challenge for many companies.

A practical example: An ESRS-based report from professional football

A look at a previously published sustainability report from a football club proved particularly insightful. With more than 1,000 employees and a turnover in excess of 500 million euros, the organisation is of a scale that is highly relevant to the ESRS.

The report initially stood out for its presentation: it was easy to read, visually appealing and clearly structured. This is particularly noteworthy given that sustainability reports often come across as highly technical. At the same time, a legitimate question arises as to whether such a visually presented format can later be translated into a management report in exactly the same way. After all, future mandatory reporting is likely to be more sober and standardised.

In terms of content, it was the structure that was particularly impressive. The report is already aligned with the ESRS, even though there was as yet no legal obligation to do so. The topics are organised according to the familiar E, S and G framework, and individual disclosure requirements are addressed in a clear and logical manner. This makes it much easier to navigate the report and demonstrates that it is intended not only as a communication tool but also as a technical working document.

What makes this report particularly successful is

Several aspects stand out in a positive light.

• A foreword from the management team setting the scene, which explains why sustainability is taken seriously from a strategic perspective.
• A clear alignment with the ESRS, even though the report was produced on a voluntary basis.
• A clear and logical structure organised by subject area and disclosure requirements.
• A plausible materiality analysis with realistic priorities.

The materiality analysis, in particular, seemed well-founded. For a football club, issues such as climate change, water consumption and the circular economy are understandably material. Other issues, such as substances of very high concern, naturally play a less significant role. It is important to note that the report does not give the impression of trying to downplay as many issues as possible. Rather, aspects such as the value chain and affected communities were also taken into account.

This suggests a serious engagement with the requirements rather than a minimalist approach to ticking off tasks.

Where transitional rules and simplifications come into play

Despite the generally positive impression, it is also clear that the report does not cover every detail in full. This is neither surprising nor problematic. Rather, it reflects the reality of many reports previously based on the ESRS: companies make use of transitional relief, omit certain key information for the time being, or rely on projections.

Reporting was particularly cautious where the financial implications of individual sustainability issues were concerned. This is understandable, not least because discussions are still ongoing in this area as to which requirements will remain in the standards in the long term.

What matters here is not so much perfection as transparency. If it is made clear where estimates have been made, where information has been simplified, or where reporting is not yet complete, this is more valuable for understanding the situation than a report that appears to be complete but lacks methodological clarity.

Internal Control System (ICS) and ESG Controlling: the crucial step towards maturity

One particularly interesting aspect of the sample report was the establishment of an internal control system for sustainability information. It is precisely here that, in future, many companies’ committed ESG work will be distinguished from truly robust reporting.

In this specific case, it was explained that a sustainability unit is working alongside the compliance function and that an ESG control framework is also to be established. This sends a strong signal. After all, sustainability reporting requires not only content, but also governance, responsibilities and documented controls.

Why is this so important? Because an audit does not mean that every single invoice or emission figure is manually checked down to the last detail. In large organisations, this is hardly practicable. What is far more important is whether the processes are set up in a plausible way and function reliably.

A simple example illustrates just how quickly problems can arise: if a manually entered figure appears somewhere in an emissions calculation and nobody can trace where it came from, the entire calculation may become unusable. In such cases, it may be necessary to redo the work, which can be time-consuming. Not because the figure was necessarily incorrect, but because there is a lack of traceability.

It therefore follows that, without an ICS, ESG reporting cannot be scaled up and will not be audit-proof.

Transition plans: Good objectives are not enough

Another interesting aspect was the approach taken to the climate transformation plan. The report in question sets out interim targets whilst also showing where the company currently stands. It is precisely this comparison that is so revealing.

After all, if emissions in the current reporting year have actually risen compared with the previous year, the question immediately arises as to how the stated reduction target is to be achieved in future. This is not evidence that the plan is flawed. But it does highlight how important it is to provide a credible rationale for the measures and pathways.

As a general rule, where interim targets are concerned, anyone who fails to meet them must, above all, provide a plausible explanation as to why this is the case. This does not automatically lead to immediate sanctions. Things will become more interesting when political climate neutrality targets are subsequently linked more closely by law to corporate obligations. These issues will increasingly occupy practitioners in the coming years.

Particularly exciting: the fans’ mobility

In the example of the football club, the fans’ travel habits were also taken into account. This makes a great deal of technical sense. When tens of thousands of people regularly travel to and from home matches, this effect can be extremely significant in Scope 3.

That is precisely why a more detailed explanation of the calculation method would have been useful. Were any assumptions made? Were surveys carried out? Were modes of transport estimated or derived statistically? Such methodological details are not merely a minor point. They play a decisive role in determining how reliable a key figure is and what questions a subsequent audit might raise.

Which ESRS topics are truly relevant to many businesses?

The practical example from professional football covers a wide range of topics. For many other organisations, particularly in the service sector, materiality will often be assessed differently. In practice, a number of typical patterns emerge.

The following are often particularly relevant:

• E1 Climate Change
• E5 Circular Economy
• S1 Own workforce
• G1 Corporate Governance

Depending on the sector, other issues may also come into play, such as water, biodiversity or the workforce within the value chain. Many companies believe that the latter, in particular, is initially underestimated. Any organisation that works with subcontractors or imposes binding obligations on suppliers regarding issues such as child labour, forced labour or health and safety at work will certainly find points of contact here.

Other issues, by contrast, are often overlooked – such as consumers and end-users in purely B2B business models, or affected communities where there are no significant points of contact. This is precisely where the value of a thorough materiality analysis becomes apparent: it helps to maintain focus without prematurely overlooking relevant risks.

Who can use such a report as a template – and who cannot

Not every company should aim to produce a comprehensive ESRS-based report. For smaller companies that do not fall within the scope of the ESRS and do not expect to do so in the future, such an approach is often too ambitious. In many cases, a pragmatic starting point via the VSME makes more sense.

The situation is different for companies that are clearly focused on the ESRS. For them, a voluntarily published report such as the example discussed can be very helpful. It demonstrates what a structure might look like, which topics arise in practice, and how technical depth can be combined with readability.