CSRD first reporting cycle: what energy and building teams learned

The first companies covered by the EU Corporate Sustainability Reporting Directive (CSRD) filed their sustainability statements in 2025, on financial year 2024 data. These "Wave 1" entities, the large listed companies, banks and insurers previously covered by the older Non-Financial Reporting Directive, were the first to work through the European Sustainability Reporting Standards (ESRS) in practice. The European Commission confirms this group applied the rules first, for reports published in 2025.

A year later the picture looks different. The Omnibus I package, proposed in February 2025 and finalized in early 2026, cut the number of companies in scope and pushed later waves back by two years. For teams that own the energy and emissions numbers, the lesson is not that the rules went away. It is that the data work behind ESRS E1 is harder and slower than most organizations budgeted for, and that work carries over to every other disclosure regime.

What actually changed in the scope reset

The original CSRD was expected to cover around 42,500 companies. The Omnibus narrowed that sharply. Under the final deal, only large undertakings with more than 1,000 employees and net turnover above 450 million euros have to report, which the Council estimates removes roughly 85 percent of companies from the original scope. The EU Council signed off on the directive on 24 February 2026.

Timing shifted too. A "stop the clock" directive adopted in 2025 postponed the second and third waves by two years, and a later relief measure meant Wave 1 filers were not required to disclose more on FY2025 and FY2026 data than they already had in their FY2024 statements. The net effect: fewer companies, later deadlines, and a smaller set of mandatory data points. None of that changes what a credible climate disclosure needs underneath it.

Lesson one: energy data was the bottleneck, not the narrative

ESRS E1, the climate standard, asks for total energy consumption, the split between renewable and non-renewable sources, and Scope 1, 2 and 3 emissions. Practitioners reported that writing the qualitative parts (policies, targets, transition plans) was manageable. The hard part was assembling complete, auditable energy consumption and emissions figures across every site, meter and commodity. KPMG's review of early ESRS reporting points to data availability and quality as recurring pain points rather than interpretation of the standard itself.

The reason is structural. A large reporter may hold hundreds of electricity, gas, water and district energy accounts spread across landlords, utilities and property managers, in different formats and billing cycles. Turning that into a single consumption number, with an audit trail back to the source document, is a data engineering problem before it is a reporting problem.

Lesson two: assurance changes how you keep the data

CSRD statements require limited assurance from an external auditor. That raised the bar on evidence. It is not enough to report a kilowatt-hour total; you need to show where each figure came from, how estimates were made for missing periods, and that the same method was applied consistently. Teams that had pulled numbers into spreadsheets once a year found that approach did not survive an assurance review.

Limited assurance is less demanding than the reasonable assurance auditors apply to financial statements, but it still requires the auditor to review the evidence behind the numbers and question anything that looks wrong. For energy data that means the auditor samples utility bills, checks that reported consumption ties back to them, and probes any large year-over-year movement. Organizations that could show that chain quickly moved through assurance with fewer findings. Those that reconstructed it from memory or from disconnected files spent the review period doing data archaeology, which is slow and expensive at exactly the moment the calendar is tightest.

Lesson three: the data outlives any single rule

The companies that handled the first cycle best treated it as a data foundation, not a filing. Their energy and emissions data now feeds several destinations at once: the EU statement, voluntary disclosures, lender questionnaires, and internal decarbonization planning. When the Omnibus changed the rules, those teams were not scrambling, because the underlying dataset did not depend on any one regulation.

That matters for Canadian and North American organizations watching from outside the EU. Canada's own Canadian Sustainability Disclosure Standards mirror the international climate baseline, and California's rules demand similar emissions data. The common thread across all of them is clean, complete, well-documented utility and energy data. Build that once and the specific reporting regime becomes a formatting exercise.

Double materiality did not let energy off the hook

CSRD introduced double materiality, the principle that a company reports both how sustainability issues affect it and how it affects the world. Some teams hoped a materiality assessment might scope climate out. In practice, climate and its energy metrics were material for almost every large organization, so the energy data work was unavoidable. The assessment shaped the qualitative disclosures, but the quantitative core, energy consumption and emissions, still had to be assembled to an auditable standard regardless of how the materiality analysis landed.

What carried into the second cycle

The relief measures reduced the number of mandatory data points, but they did not remove the core climate metrics. Total energy consumption, the renewable and non-renewable split, and gross Scope 1, 2 and 3 emissions remain the backbone of ESRS E1. Wave 1 filers found that once they had built a clean energy dataset for the first statement, the second cycle was far cheaper, because the collection and estimation methods were already documented and repeatable. The cost of the first cycle sat almost entirely in standing up the data, not in maintaining it.

That is the payoff worth planning for. A reporter that treats the first year as a one-time scramble pays the full cost again every year. A reporter that builds a durable pipeline pays it once. The Omnibus reset the deadlines for later waves, which gives those companies more room, but the smart use of that room is to build the data foundation now rather than wait for the deadline to force a rushed project with an auditor already booked.

A practical checklist from the first cycle

1. Inventory every energy account and meter across the portfolio, including tenant and landlord-controlled sites.
2. Centralize bills and interval data in one place, with the source document attached to every figure.
3. Document estimation rules for missing or partial periods before assurance, not during it.
4. Separate location-based and market-based Scope 2 so both can be reported.
5. Reconcile totals against prior periods to catch gaps and double counting early.

How MartinAI fits

MartinAI is built to remove the manual work of collecting, cleaning and structuring utility and energy data across any commodity and any utility. It ingests bills and interval data, extracts the values that ESRS E1 and equivalent standards ask for, and keeps each figure linked to its source document so an assurance team can trace it. Instead of rebuilding a dataset every reporting season, energy and sustainability teams work from one continuously updated record. MartinAI does not certify or file your disclosure; it gives your reporting and audit teams data they can stand behind.