FAQCSRDESRS

CSRD value chain estimates When direct ESRS data is not available

ESRS allows estimates for upstream and downstream value chain information when required information cannot be collected after reasonable efforts.

The estimate still needs a disclosed basis, a level of accuracy, limitations, and planned actions to improve data quality where applicable.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 25, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 25, 2026
Overview

Under CSRD reporting with ESRS, value chain information is not a request to survey every supplier, customer, or indirect relationship. The reporting question is whether material impacts, risks, or opportunities require upstream or downstream value chain information, and whether direct data is available after reasonable efforts.

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4 of 4 questions
Question 1

Can CSRD reporters use estimates for value chain information under ESRS?

Yes. ESRS 1 requires the sustainability statement to include material upstream and downstream value chain information where it is needed to explain material impacts, risks, and opportunities. It also says that if the undertaking cannot collect the required value chain information after reasonable efforts, it shall estimate the information using reasonable and supportable information, including sector-average data and other proxies.

That does not make estimates a shortcut around materiality. ESRS 1 says value chain information is extended only to the parts of the value chain where the matter is material, and estimates must still meet the qualitative characteristics of sustainability information.

  • Start with the material impact, risk, or opportunity, not a full population of every value chain actor.
  • Record what direct information was requested or reviewed and why it was unavailable, incomplete, or unreliable.
  • Use supportable indirect information such as sector averages, country or regional risk data, sample analyses, market data, peer group data, or product-level proxies where those inputs fit the matter.
  • Do not use a proxy if it would make the disclosed metric arbitrary or misleading for the material matter.
Citations
Recommended next step

Review value chain estimates before reporting

Check whether each CSRD value chain estimate has a materiality link, a supportable proxy, documented limits, and a clear accuracy-improvement plan.

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Question 2

What should be disclosed when an ESRS value chain metric uses estimates?

When metrics include value chain data estimated from indirect sources, the disclosure should identify the metric, explain the basis for preparation, describe the resulting level of accuracy, and, where applicable, describe planned actions to improve accuracy in the future.

ESRS also treats estimation and outcome uncertainty as normal in sustainability reporting. The key control is transparency: users should understand the significant uncertainties, assumptions, and limits that affect the reported quantitative metric or monetary amount.

  • Metric affected: name the datapoint or entity-specific metric that includes estimated upstream or downstream value chain data.
  • Reason for estimation: explain why direct primary information was not available after reasonable efforts.
  • Inputs and method: name the proxy data source type and the main calculation assumptions without overstating precision.
  • Accuracy statement: describe whether accuracy is high, moderate, limited, or otherwise constrained, and why.
  • Improvement plan: state planned actions such as supplier data collection, better geographic segmentation, sampling, system changes, or updated proxy selection.
Citations
Question 3

How should teams document reasonable efforts before using a value chain estimate?

The documentation should show why an estimate was needed and why the chosen proxy is supportable for the material matter. It should be specific enough for reporting, finance, procurement, sustainability, and assurance reviewers to follow the same trail from source data to disclosure.

A useful file separates unavailable primary data from the estimation method. For example, a supplier non-response problem is different from a downstream-use problem where measuring each end user would be impracticable and a product-use estimate is more relevant.

  • Value chain scope: affected product, service, geography, activity, supplier group, customer group, or indirect business relationship.
  • Materiality link: the impact, risk, or opportunity that makes the value chain information necessary.
  • Reasonable-efforts log: requests made, internal data reviewed, public data reviewed, supplier or customer limits, and known reliability issues.
  • Proxy selection memo: why the selected sector, country, product, sample, market, peer, or other indirect data is reasonable and supportable.
  • Assumption register: variables, data vintage, exclusions, sensitivity points, and consistency with related financial or operational assumptions where relevant.
  • Review control: preparer, reviewer, approval date, changes from the prior period, and the trigger for revisiting the estimate.
Citations
Question 4

What are the limits of using estimates for CSRD value chain reporting?

Estimates are acceptable only within the ESRS reporting logic. They cannot replace the materiality assessment, hide a known data gap, or turn unsupported information into a reliable metric. ESRS 1 says that incorporating sector-average data or other proxies must not result in information that fails the qualitative characteristics of information.

EFRAG IG 2 also warns that quantitative measures of indirect impacts are not always the most relevant disclosure. If a calculated footprint would be too arbitrary or would not explain the undertaking's contribution to managing a material impact, teams should reassess whether another ESRS disclosure, narrative explanation, policy, action, target, or entity-specific metric better explains the matter.

  • Do not estimate every actor when ESRS only requires material upstream or downstream value chain information.
  • Do not present proxy output as primary data from a supplier, customer, facility, or worker group.
  • Do not reuse a proxy when geography, product mix, activity, or business relationship changes make it stale.
  • Do not ignore contradictory information received before the management report is approved if it provides evidence about conditions at period end.
  • Do not assume buying power or leverage changes materiality; it may affect data access and improvement plans, but materiality still follows impacts, risks, and opportunities.
Citations
Primary sources

References and citations

Commission Delegated Regulation (EU) 2023/2772
data.europa.eu
Referenced sections
  • The Delegated Regulation is the official EU legal act adopting the ESRS set used for CSRD sustainability reporting.
"sustainability reporting standards"
EFRAG IG 2: Value Chain Implementation Guidance
efrag.org
Referenced sections
  • EFRAG IG 2 explains that proxies may be necessary but must be transparent, relevant, and improved over time as data quality develops.
"improve accuracy in the future"
European sustainability reporting standards (ESRS)
xbrl.efrag.org
Referenced sections
  • ESRS 1 limits value-chain reporting to material information and requires estimates to preserve the qualitative characteristics of sustainability information.
"only the inclusion of material"
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