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Handling Data Gaps in the CSRD Report

What do the ESRS require?

The following requirements are based on ESRS 1, Section 7.2–7.5:

  1. Estimates are permitted If data cannot be directly measured, it may be estimated (ESRS 1, 7.2).

  2. Transparency is mandatory You must disclose:

  • which data has been estimated

  • which assumptions were used

  • how the values were calculated

The objective is to make key uncertainties understandable for users (ESRS 1, 7.2).

  1. Measurement uncertainty is acceptable Even high levels of uncertainty are allowed, as long as assumptions are clearly described (ESRS 1, 7.3).

  2. Consistency with financial data Assumptions should, where possible, be consistent with those used in the financial statements (ESRS 1, 7.3).

  3. Subsequent updates New information after the reporting period must be considered (ESRS 1, 7.4):

  • Update estimates if they relate to existing conditions

  • Explain events after the reporting date where relevant

  • Ensure comparability

If estimates change retrospectively (ESRS 1, 7.5):

  • Adjust comparative figures where possible

  • Keep methodologies consistent

Example: Handling missing consumption data

If not all consumption data is available at the time of reporting, companies must work with preliminary or estimated values.

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Typical case: The CSRD report is finalized in February for audit in March, while some data (e.g. electricity consumption for December) only becomes available in March.

If data for individual months is missing, you have two options:

A) Use extrapolation

Use extrapolation if interim consumption data is available and can be reliably projected.

  • Typical example: Estimate November and December electricity consumption based on previous monthly values

  • Requirement: No significant deviations from prior year or known trends

B) Use prior-year values

Use prior-year values if no reliable extrapolation is possible.

  • Typical example: Use prior-year heating data

  • Requirement: Comparable conditions (e.g. usage, weather, locations)

Choose the method that provides greater traceability.

If necessary, you can agree with your auditor to transparently provide missing data once it becomes available. This is likely also the case for revenue, which is typically only finalized after audit.

How do I document assumptions in Tanso?

Document all assumptions directly in the comment field of the respective data point in Tanso. Ensure the following information is included:

  • Type of estimate (extrapolation or prior year)

  • Data basis

  • Assumptions and calculation logic

  • Degree of uncertainty (if relevant)

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