CSRD and ESRS Value-Chain Data and Estimation

Start from the material impacts, risks, and opportunities identified under ESRS. Value-chain information is relevant when those matters arise through business relationships, including indirect relationships beyond direct contracts, or when a disclosure requirement specifically calls for value-chain coverage.

Do not expand the consolidation perimeter just because value-chain information is included. EFRAG's non-authoritative IG 2 explains that the sustainability statement uses the same reporting undertaking as the financial statements, while required value-chain information extends selected disclosures to upstream and downstream relationships.

Keep two legal-status checks separate from the ESRS data test. Directive (EU) 2026/470 must be transposed into national law by 19 March 2027, and the Article 29ca voluntary-standard delegated act adopted on 3 July 2026 must clear scrutiny before it applies. A protected undertaking may eventually refuse a sustainability-reporting request that exceeds the voluntary standard, but the directive does not prohibit voluntary sharing, and the cap is limited to requests made for Accounting Directive sustainability reporting.

Direct collection is practical where the undertaking has a substantial relationship, usable product parameters, or enough influence to set a reliable reporting request. EFRAG gives examples such as major direct (tier 1) suppliers, customers that are end users, questionnaires, surveys, and audits.

The collection process should be designed as a control, not as an unmanaged email exercise. Each request should state the ESRS datapoint or entity-specific metric, the reporting period, units, calculation instructions, evidence expected, respondent role, and review owner.

Under the 2023 ESRS, when required value-chain information cannot be collected after reasonable efforts, the undertaking must estimate it using reasonable and supportable information available without undue cost or effort, such as sector averages and other proxies. Document the source, method, reliability, and limitations of any product-level, regional, public-report, database, or other indirect input.

A defensible estimate explains why direct data was not available, why the selected proxy is the best available input, what assumptions drive the result, and how sensitive the metric is to changes in those assumptions. It should be clear whether the estimate is used for materiality assessment, a required metric, or an entity-specific disclosure.

The sustainability statement should not hide estimated value-chain metrics inside polished narrative. ESRS and EFRAG guidance point to disclosure of the basis for preparation, the level of accuracy, and planned actions to improve accuracy when metrics include estimated value-chain data from indirect sources.

Limitations should be precise enough for a reviewer to understand the uncertainty without overstating weakness. State the estimated portion, the unavailable primary data, the proxy source, the quality concerns, the likely direction of uncertainty if known, and the improvement plan for the next reporting cycle.

Value-chain estimates need enough evidence for an assurance practitioner to follow the reporting process, challenge the assumptions, and test whether the sustainability information complies with ESRS. CSRD assurance covers the reporting standards, the process used to identify reported information, digital markup, and Taxonomy Article 8 reporting where applicable.

Build the evidence file around the estimate itself: source hierarchy, direct-data attempts, proxy selection, method, calculation, review, limitation wording, and final disclosure. The control should show what changed from source input to reported number or narrative.