CSRDValue-chain dataESRS

CSRD and ESRS Value-Chain Data and Estimation

Use this page to decide when ESRS value-chain information is needed, when estimates are acceptable, and what evidence should support the method.

The focus is practical reporting control: direct data where reasonable, proxies where justified, transparent limitations, and assurance-ready documentation.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

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

ESRS value-chain reporting is not a request to survey every supplier, distributor, customer, or end user. It is a materiality-driven exercise: identify where impacts, risks, and opportunities are likely to arise across own operations and upstream or downstream relationships, collect reliable direct information where proportionate, and estimate missing information when primary data cannot be obtained after reasonable efforts.

Section 1

When ESRS value-chain information is needed

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 reporting perimeter just because value-chain information is included. EFRAG's value-chain guidance explains that reporting boundaries correspond to the entities in the consolidated financial statements, while value-chain information covers the relationships those entities have with upstream and downstream counterparties.

  • Map the business model, sourcing, production, distribution, use, and end-of-life stages where material impacts, risks, or opportunities may arise.
  • Separate own-operation data from upstream supplier data, downstream customer or use-phase data, and indirect source data.
  • Record which ESRS disclosure or entity-specific disclosure needs the value-chain information.
  • Avoid asking every value-chain actor for every datapoint; focus collection on material matters and disclosures that require the information.
  • Keep a written boundary note explaining whether the issue concerns the consolidation perimeter, a value-chain relationship, or both.
Sources for this answer
European sustainability reporting standards (ESRS)
Defines value chain, actors in the value chain, material impacts, and the ESRS reporting areas that determine when value-chain information is relevant.
EFRAG ESRS implementation guidance documents
Identifies EFRAG IG 2 Value Chain as non-authoritative implementation guidance for applying ESRS value-chain requirements.
Section 2

How to collect direct value-chain data

Direct information is strongest 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 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.

  • Prioritise direct requests for high-severity impacts, high-exposure suppliers, key downstream use cases, and metrics that materially affect the sustainability statement.
  • Use supplier questionnaires only when the questions map to specific ESRS disclosures, assumptions, or metric inputs.
  • Track non-response, partial response, late response, inconsistent units, missing evidence, and management override as data-quality issues.
  • Preserve source extracts, request logs, supplier attestations, audit reports, survey instruments, and reviewer comments with the final datapoint.
  • Update procurement, sales, and partner onboarding controls so future reporting periods can collect better primary data.
Sources for this answer
EFRAG ESRS implementation guidance documents
Supports the practical collection approach by identifying EFRAG IG 2 Value Chain as the implementation guidance for value-chain reporting.
European sustainability reporting standards (ESRS)
Supports tying requests to ESRS disclosure requirements, metrics, targets, and material impacts, risks, and opportunities.
Section 3

When estimates and proxies are acceptable

Estimation is allowed when primary value-chain information cannot be collected with the required reliability after reasonable efforts. The method should use reasonable and supportable information available without undue cost or effort, including sector averages, product-level proxies, regional data, public reports, databases, and other indirect sources.

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.

  • Document the reasonable-effort steps attempted before estimating: who was contacted, what was requested, response evidence, timing, and why the result was unusable or incomplete.
  • Choose proxies that match the actual activity as closely as possible: product, sector, geography, process, use pattern, customer type, or supplier tier.
  • Record the calculation method, source vintage, conversion factors, allocation logic, exclusions, and reviewer approval.
  • Use sensitivity analysis where a small change in a major assumption could alter a material conclusion.
  • Do not use estimates to avoid disclosure; use them to report missing material value-chain information transparently when direct data is not reasonably available.
Sources for this answer
EFRAG ESRS implementation guidance documents
Supports the use of EFRAG IG 2 for reasonable-effort, indirect-source, sector-average, and proxy guidance on value-chain information.
Commission Delegated Regulation (EU) 2023/2772
Official ESRS legal source for the adopted sustainability reporting standards, including value-chain definitions and estimation disclosures.
Section 4

What limitations to disclose for estimated value-chain data

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.

  • Flag metrics that combine direct supplier data with estimates so the mixed basis is visible.
  • Explain known limitations such as missing tier 2 or tier N data, supplier non-response, unavailable customer use data, weak location specificity, or outdated sector averages.
  • Avoid false precision; round, range, or qualify outputs when the underlying evidence does not support exact figures.
  • Connect each limitation to an owner and improvement action, such as new contract data clauses, supplier-system onboarding, source refresh, or methodology review.
  • Keep limitations consistent across narrative disclosure, datapoint inventory, management review materials, assurance files, and digital tagging documentation.
Sources for this answer
European sustainability reporting standards (ESRS)
Supports the need to identify value-chain information, assumptions, estimates, and disclosures in the ESRS sustainability statement.
EFRAG ESRS implementation guidance documents
Supports disclosing the basis, accuracy, and improvement plan for value-chain metrics that rely on indirect-source estimates.
Section 5

Evidence controls for assurance readiness

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.

  • Maintain an estimate register with ESRS disclosure reference, material IRO, value-chain stage, data owner, calculation owner, approver, and reporting period.
  • Attach primary-data requests, responses, non-response evidence, supplier audit records, public-source extracts, and proxy-source metadata.
  • Version the model, assumptions, calculation workbook, source refresh date, change log, and management sign-off.
  • Review estimates for completeness, consistency with prior-period methods, sensitivity to major assumptions, and alignment with the stated limitations.
  • Prepare a reviewer trail that links the estimate to the sustainability statement text, digital tagging review, and assurance request list.
Sources for this answer
Directive (EU) 2022/2464 on corporate sustainability reporting
Supports assurance-readiness guidance because CSRD requires assurance over sustainability reporting compliance, the reported-information identification process, digital markup, and Taxonomy Article 8 reporting.
IAASB ISSA 5000 overview
Provides assurance context for sustainability assurance engagements and a general assurance standard that can be relevant to ESRS assurance work.
Recommended next step

Build an assurance-ready value-chain estimate file

Turn ESRS value-chain estimates into controlled evidence: direct-data attempts, proxy choices, calculation methods, limitations, approvals, and disclosure links.

Research workflow
Open Research Copilot

Answer CSRD and ESRS value-chain reporting questions with cited source material.

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Discuss CSRD evidence controls

Review value-chain estimate methods, limitations, and assurance evidence with Sorena.

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Primary sources

References and citations

Commission Delegated Regulation (EU) 2023/2772
data.europa.eu
Referenced sections
  • Official ESRS legal source for the adopted sustainability reporting standards, including value-chain definitions and estimation disclosures.
"sustainability reporting standards"
Directive (EU) 2022/2464 on corporate sustainability reporting
data.europa.eu
Referenced sections
  • Supports assurance-readiness guidance because CSRD requires assurance over sustainability reporting compliance, the reported-information identification process, digital markup, and Taxonomy Article 8 reporting.
"limited assurance engagement"
IAASB ISSA 5000 overview
iaasb.org
Referenced sections
  • Provides assurance context for sustainability assurance engagements and a general assurance standard that can be relevant to ESRS assurance work.
"Sustainability Assurance 5000"
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