How to Write an ESG Report
Without a Consultant
In 2025, thousands of Romanian companies come under CSRD scope and must publish their first sustainability report. If you lack the budget for an external consultant costing €30,000–80,000, this guide shows you how to produce a solid ESG report in 10 steps using free resources and a clear framework.
Who must produce an ESG report under CSRD?
The CSRD Directive (2022/2464/EU) significantly extends reporting obligations relative to its predecessor NFRD. Inclusion criteria are cumulative: a company falls within CSRD scope if it meets at least two of three criteria: more than 250 employees, net turnover exceeding €40 million, or total balance-sheet assets above €20 million. Listed companies regardless of size are in scope from 2026.
A conservative estimate places the number of affected Romanian companies at approximately 500 in the first wave (FY 2024, reporting in 2025), growing to 3,000–4,000 in subsequent phases. SMEs not directly obligated will feel the pressure indirectly through the supply chain: their large customers will request emission data to calculate their own Scope 3.
Structure of a CSRD sustainability report
The CSRD sustainability report is based on the European Sustainability Reporting Standards (ESRS), adopted by Delegated Regulation (EU) 2023/2772. There are 12 thematic standards grouped under three pillars: Environmental (E), Social (S) and Governance (G). Not all are simultaneously mandatory — the company first conducts a double materiality assessment to identify which aspects are relevant to its business model.
| Standard | Topic | Key requirements |
|---|---|---|
| ESRS E1 | Climate Change | GHG emissions Scope 1, 2, 3; reduction targets; transition plan |
| ESRS E2 | Pollution | Pollutants in air, water, soil; hazardous substances |
| ESRS E3 | Water and Marine Resources | Water consumption; water stress; aquatic biodiversity |
| ESRS E4 | Biodiversity and Ecosystems | Nature impact and dependencies; sensitive areas |
| ESRS E5 | Resource Use and Circular Economy | Resource inputs, waste, design for recycling |
| ESRS S1 | Own Workforce | Working conditions, diversity, health and safety |
| ESRS S2 | Workers in Value Chain | Labour rights at suppliers, due diligence |
| ESRS S3 | Affected Communities | Local impact, community rights |
| ESRS S4 | Consumers and End Users | Product safety, data privacy |
| ESRS G1 | Business Conduct | Anti-corruption, whistleblower protection, supplier relations |
10 steps for your first ESG report without a consultant
- Verify whether you are in scope — Apply the criteria: employees, turnover, total assets. If 2 of 3 criteria are met, you are obligated.
- Build a minimal internal team — You need at least: a financial officer (balance sheet, procurement data), an HR officer (employee data), a technical/operations officer (energy and fuel consumption).
- Conduct the double materiality assessment — Use the free EFRAG (European Financial Reporting Advisory Group) guide available at efrag.org. Document the process and results.
- Collect data for material standards — Start with E1 (climate) and S1 (employees). Use data already available in the company: utility bills, payroll records, vehicle registers.
- Calculate GHG emissions — Scope 1 and Scope 2 are calculable from the above data and public emission factors (Romania electricity grid: ~0.265 kg CO₂/kWh; DEFRA for fuels). Use our free Scope 2 calculator.
- Document policies and processes — ESRS requires a description of existing ESG policies. If not yet formalised, now is the time to create them: environmental policy, anti-discrimination policy, code of ethics.
- Draft the report — ESRS structure requires a general context section (ESRS 2) and sections for each material standard. A typical first report for an SME: 30–60 pages.
- Obtain auditor validation — CSRD requires a sustainability audit with limited assurance from 2025 and reasonable assurance from 2028. Contact an ISAE 3000 auditor before year-end.
- Integrate into the annual report — The sustainability report is published as part of the annual report or separately, with a cross-reference, per Trade Registry requirements.
- Set up a continuous system — ESG data collection is not a one-off project. Install a monthly data collection system (spreadsheet or simple tool) to ease reporting in subsequent years.
Frequently asked questions about ESG reporting
What happens if I do not submit the ESG report on time?
CSRD sanctions are set by each EU member state but must be effective and dissuasive. In Romania, Law 236/2024 transposing CSRD provides for fines of up to 3% of annual turnover for non-compliance. Additionally, companies with deficient ESG reporting may be excluded from European public tenders and from the supply chains of large companies.
Can the ESG report be in Romanian or must it be in English?
The report is submitted in the official language of the member state where the company is registered — in Romanian for Romanian companies. If the company has international shareholders or partners, an English version is commercially useful but not legally required.
Does ESRS E1 require reduction targets or only emission reporting?
ESRS E1 requires both emission reporting (Scope 1, 2, and material Scope 3) and the declaration of reduction targets and a climate transition plan if the company has made such commitments. If you have no targets, you must explain why and whether you plan to set them. Absence of targets is not per se non-compliant, but reduces report credibility.
How long does preparing a first ESG report take?
For a company with 100–500 employees and no prior experience, the first ESG report takes 4–9 months: 1–2 months for materiality assessment, 2–3 months for data collection and calculations, 1–2 months for drafting and review, 1–2 months for assurance audit. From the second year onward, the process reduces to 2–4 months if data collection systems are in place.
Must I report my suppliers' emissions (Scope 3 Cat. 1)?
Yes, if Scope 3 Cat. 1 is material — meaning if emissions from purchased goods and services are significant relative to total emissions. For manufacturing companies this is almost always the case. You can use the spend-based method as an initial estimate and improve precision progressively. Read our complete Scope 3 guide.
Need help with the carbon component of your ESG report?
CarbonDRI calculates GHG emissions Scope 1, 2 and 3 for CSRD/ESRS E1 reporting, with documented methodology, updated emission factors and audit-ready reports.
Request GHG Calculation for ESG Report →See also: Scope 3 Guide · Full CSRD Guide · LCA Services