ESRS Reporting: Why Most Organisations Get It Wrong (Without Realising It)
As organisations across Europe prepare for ESRS reporting under the CSRD, many assume the challenge is technical: understanding standards, datapoints, and disclosure requirements.
In practice, the biggest ESRS failures rarely come from missing knowledge.
They come from how organisations approach ESRS in the first place.
Based on our work with sustainability, ESG, and compliance teams, we consistently see the same structural mistakes — mistakes that quietly increase workload, create assurance risk, and lead to costly rework later on.
Below are some of the most common ESRS pitfalls organisations fall into — often with the best intentions.
1. Treating ESRS as “just another report”
A common starting point is to treat ESRS like a traditional sustainability report: gather information, draft disclosures, and aim to produce a document.
The problem?
ESRS is not a document exercise — it is a system.
Without a repeatable process that links governance, data, controls, and documentation, disclosures quickly become inconsistent and difficult to defend under assurance.
Many organisations only realise this when auditors start asking how decisions were made — not just what was reported.
2. Starting with the standards instead of double materiality
ESRS standards are detailed and extensive. It’s tempting to start by working through datapoints and requirements one by one.
This almost always leads to:
- overreporting
- wasted effort
- unclear sustainability messages
A defensible ESRS report does not start with the standards.
It starts with double materiality, properly planned and documented.
When materiality is weak, everything downstream becomes harder.
3. Weak or informal stakeholder engagement
Stakeholder engagement is sometimes treated as a box-ticking exercise — a survey here, a workshop there.
Under ESRS, this is risky.
If engagement lacks structure, purpose, and documentation, materiality decisions become difficult to defend. Assurance teams look closely at how stakeholder input influenced outcomes — not whether engagement happened at all.
4. Overreporting to “be safe”
One of the most damaging ESRS instincts is the idea that “more disclosure is safer disclosure”.
In reality, overreporting:
- obscures what is truly material
- increases audit burden
- weakens clarity for users of the report
ESRS rewards focus, not volume. Achieving that focus requires planning — not last-minute filtering.
5. Making key judgments without an audit trail
Every ESRS report involves judgment calls:
- scope decisions
- prioritisation
- assumptions
When these judgments are not clearly documented, organisations expose themselves to assurance findings and credibility issues — even if the final disclosures look reasonable on the surface.
6. Leaving data and systems to the end
Many teams draft ESRS disclosures first and only later realise that:
- data owners are unclear
- systems don’t support requirements
- controls are missing
This creates stress, rework, and compliance risk — often late in the reporting cycle.
The common thread behind all these mistakes
Across all of these issues, one pattern stands out:
Lack of structured planning.
Without planning, ESRS becomes reactive.
With planning, ESRS becomes manageable, defensible, and strategically useful.
Planning is what connects:
- materiality
- stakeholder engagement
- data collection
- documentation
- assurance readiness
- digital reporting
And yet, it’s the part most organisations underestimate.
Want the full list of ESRS mistakes — and how to avoid them?
We’ve put together a concise, practical guide that outlines:
- the top ESRS mistakes organisations make
- why they happen
- what to do differently to avoid rework, confusion, and assurance risk
The guide is designed for sustainability, ESG, compliance, audit, and reporting professionals who want a clear, structured approach to ESRS — without guesswork.
Download the free PDF: Top ESRS Mistakes to Avoid
Why we created this guide
ESRS does not fail because organisations don’t care.
It fails when complexity isn’t matched with structure.
The goal of this guide is not to overwhelm — but to help teams recognise early warning signs and approach ESRS more confidently and responsibly.
About FBRH
FBRH is one of the original GRI Certified Training Providers, supporting organisations and professionals globally with practical, implementation-focused sustainability reporting education.
Our work focuses on clarity, structure, and real-world application — helping teams build internal ESRS capability rather than reliance on ad-hoc fixes.
For those seeking a structured, GRI-certified pathway to build ESRS capability, further training options are available — but the guide stands on its own as a practical starting point.