In a context of major regulatory overhaul and simplification, the CSRD (Corporate Sustainability Reporting Directive) is at the forefront. But beyond compliance, a strategic challenge is emerging: how can this requirement be transformed into a genuine corporate project that promotes sustainable performance? To address this issue, Cigref, in partnership with the DFCG (The French Association of CFOs and Financial Controllers), has published its conclusions and recommendations on this subject in its new report, ‘Implementation of the Corporate Sustainability Reporting Directive (CSRD): Challenges and prospects for digital departments’.
CSRD: from regulatory constraint to value management
The CSRD (Corporate Sustainability Reporting Directive), which came into force on 1 January 2024, imposes a harmonised non-financial reporting framework at European level. Although the ‘Content’ directive of December 2025 recently raised the eligibility thresholds (companies with more than 1,000 employees and €450 million in turnover), it has not dampened the enthusiasm of organisations already committed to the directive, which see it as an opportunity to refine their processes.
The publication of the report ‘Implementing the CSRD: challenges and prospects for digital departments’ is the result of a year of sharing and reflection by Cigref members, in partnership with the DFCG (The French Association of CFOs and Financial Controllers): their initial objective was to familiarise themselves with the concept and specific terminology of the CSRD directive, then to identify best practices in governance, management and inter-departmental collaboration (finance, CSR, digital, etc.) based on initial feedback from participating companies. The report then analyses the implications of the CSRD for digital departments in particular (as contributors to and orchestrators of this standard) and proposes avenues for the tooling and industrialisation of reporting processes via a set of common specifications.
The initial implementation phases have revealed major challenges for large-scale deployment. The complexity of the CSRD’s legal and technical arsenal, particularly the ESRS standards, requires a familiarization period for all contributors. The double materiality analysis, the cornerstone of the CSRD, is proving to be a demanding exercise that is complex to implement and update, and involves many stakeholders to make the exercise relevant. The management of data points, particularly the narrative part, presents significant challenges in terms of redundancies and harmonisation. Finally, data governance and the distribution of responsibilities are also major concerns, especially in decentralised and international group contexts.
Faced with these challenges, the CSRD ultimately stands out as a business transformation project that also presents its share of opportunities. Take, for example, double materiality analysis, which requires performance to be assessed from two perspectives: financial materiality (the impact of ESG issues on the company’s economic and financial performance) and impact materiality (the company’s impact on the planet and society). This exercise forces companies to engage in unprecedented introspection about their impacts and dependencies, which naturally leads them to evolve their business models towards greater resilience.
Open and strategic governance
Analysis of the first waves of implementation of the directive highlights that governance is the primary factor in the success of a CSRD project:
One of the keys to success is tripartite collaboration between Finance, CSR and IT. This joint leadership must involve the Executive Committee and employee representative bodies from the outset in order to embed sustainability in the company’s committee structure.
- To avoid bottlenecks, companies recommend involving auditors at a very early stage, starting with the double materiality analysis and the definition of IROs (Impacts, Risks, Opportunities).
- The organisation must also clarify responsibilities by appointing a single Data Owner for each type of data. A gradual approach is recommended: start with a manual pilot phase to master the basics before embarking on full-scale industrialisation.
- A systematic gap analysis between the existing situation and the requirements of ESRS standards is an essential prerequisite for identifying harmonisation needs.
Finally, this governance must go beyond simple risk management to focus on strategic opportunities. By breaking down silos, CSRD becomes a driver of innovation capable of rethinking the company’s business model in light of sustainability issues.
The IT department, architect of sustainable performance
The goal is to achieve a level of processing rigour equivalent to that of finance. To achieve this, the IT department must deploy a robust data architecture (data platform, data warehouse) and implement strict governance including identified data owners and a rigorous data catalogue.
By controlling the ESG data lifecycle in this way, the IT department is no longer content with ensuring compliance: it becomes a strategic partner in the resilience and sustainability of the company’s business model.
Identified technical best practices include:
- Investing in a robust data architecture: favouring a central data platform to aggregate heterogeneous flows and ensure interoperability.
- Ensuring auditability: implementing a rigorous data catalogue and data lineage to trace information from the raw source to the final report.
- Automating data collection: deploying workflows and interfaces with source systems (ERP, HRIS) to improve data reliability and reduce manual data entry.
- Skills development: acculturate IT teams to ESG semantics to enable them to effectively challenge business needs.
CSRD thus transcends simple compliance to become a lever for transformation: it invites organisations to overhaul their business model by unifying financial and extra-financial performance within a global strategy.
