How to run a CSRD gap analysis
How to compare what you can report today with what the ESRS will ask for, rank the gaps, and turn them into a plan with owners and dates.
A gap analysis answers one question: between what you can evidence today and what you will have to report, what is missing? Done early, it tells you how much time, money and data work to plan for. Done late, it becomes a rush.
Before you start: confirm you are in scope
The amended CSRD, as reported by law-firm summaries of Directive (EU) 2026/470, covers EU undertakings with more than 1,000 employees and net turnover above EUR 450 million, with reporting for financial years beginning on or after 1 January 2027 for companies not already reporting. Member States must transpose by 19 March 2027, so national detail varies. Read who has to report and when first.
Step 1: Choose your standard version
Companies reporting for a financial year starting in 2026 can, per advisory summaries of the Commission's package, choose between the original ESRS, the revised ESRS early, or the original with certain reliefs, and must say which they used. The revised ESRS apply to years beginning on or after 1 January 2027. Confirm the final rules with your adviser before you commit to a baseline.
Step 2: Complete the materiality assessment first
Gaps only make sense against material topics. If you have not done the assessment, start there: double materiality step by step.
Step 3: List the datapoints required
Take the datapoint list for your material topics. Put one row per datapoint in a spreadsheet with columns for: topic, datapoint, data type (number, narrative, policy), required or voluntary, and the owner.
Step 4: Rate your current position
For every row, mark one of four states.
| State | Meaning |
|---|---|
| Ready | You have the data, a documented method and evidence |
| Partial | You have some data or an undocumented method |
| Missing | You do not collect this today |
| Not applicable | Not relevant, with a written reason |
Step 5: Rank the gaps
Rank by effort and by risk. A missing greenhouse gas inventory is high effort and high risk. A missing policy statement is low effort. Start with items that are quick and block others.
Step 6: Check systems and controls
Ask where the data lives, who changes it and how it is checked. Reporting data will need the same discipline as financial data, because it will be assured. Spreadsheets without version control are a common weak point.
Step 7: Plan the remediation
Convert each gap into a task with an owner, a due date and the evidence it will produce. Add a cost estimate, and decide where software or an adviser is worth paying for.
Step 8: Test with a dry run
Prepare a draft of the report for a recent year and see where it breaks. Have someone ask for the evidence behind ten figures chosen at random.
Get a head start
Use our CSRD readiness checklist and compare options in best CSRD reporting software.
ERM
Sustainability consultancy advising on ESG strategy, climate and regulatory reporting.
Greenativity
German sustainability consultancy offering double materiality assessments, CSRD workshops and reporting support with its own Caribou software.
Systain
Hamburg sustainability consultancy focused on supply chains, climate and human rights for retail and consumer goods companies.
Sustainly
Czech ESG reporting and carbon accounting workspace for SMEs based on VSME and GRI, with physical climate risk screening.
KPMG
Global network offering ESG assurance, CSRD readiness and sustainability advisory.
Anthesis
Sustainability consultancy covering strategy, carbon, reporting and target setting.
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Official sources
- EFRAG ESRS implementation guidance, including the list of datapoints
- European Commission: corporate sustainability reporting
This guide is general information, not legal, tax or investment advice. Rules change; check the official sources and talk to an adviser before you rely on it.
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