Enabling Positive Impact

Closing the 5 Hidden Data Gaps in ESRS Reporting

Most companies begin their ESRS reporting journey expecting a heavy workload. What many do not expect is that the real challenge is not the reporting framework itself. It is the missing, inconsistent, or unverifiable data that makes compliance feel impossible.

As filing deadlines approach, organizations often discover that the numbers they need are scattered across different teams, buried in disconnected systems, or still living in outdated spreadsheets. These gaps slow down progress, weaken credibility, and increase the risk of non-compliance with the Corporate Sustainability Reporting Directive (CSRD).

Based on our experience guiding companies through ESG Data and CSRD Reporting Readiness, five data blind spots appear again and again. The good news is that each one can be solved with a structured approach and the right data foundations.

Below are the five hidden gaps that hold companies back and how to close them with confidence.

1. Scope 3 Emissions: Moving From Estimates to Actual Numbers

Most businesses have at least some level of greenhouse gas data for Scopes 1 and 2. Scope 3 is where the complexity begins. These emissions occur outside a company’s direct control but often represent more than 70 percent of the total footprint. As a result, even small data inconsistencies can dramatically alter reported figures.

The biggest challenge comes from relying entirely on industry averages or generic emissions factors. While these tools can be useful starting points, they do not reflect the real impacts of your supply chain. Regulators are becoming more critical of companies that rely too heavily on estimates without showing a clear plan for improvement.

To close this gap, organizations need a way to gradually move from high-level estimates to supplier-specific data. This includes:

  • Gathering primary data from suppliers rather than applying generic factors.
  • Identifying high-impact categories like purchased goods, transportation, and product use.
  • Building long-term processes for supplier engagement, education, and verification.
  • Integrating Scope 3 data into purchasing, logistics, and product decision-making.

A mature Scope 3 process does not appear overnight. It is an ongoing improvement pathway. Companies that start building these capabilities now will be significantly more prepared for future CSRD expectations.

2. Biodiversity Impacts: Measuring What Was Once Invisible

Biodiversity data is one of the newest and least understood areas of ESRS reporting. Many organizations are unsure where to begin because these impacts are highly location specific and often difficult to quantify. Even companies with established environmental programs may only have fragmented information about land use, water withdrawal, protected landscapes, or species risks.

This gap becomes more visible with ESRS E4, which requires organizations to provide detailed, measurable insights into their interactions with ecosystems. The challenge is that many companies do not yet have monitoring systems that track biodiversity outcomes in a consistent way.

Closing this gap requires a blend of scientific data and operational awareness. Practical steps include:

  • Mapping where business activities intersect with sensitive ecosystems.
  • Using geospatial data to identify potential hotspots or risk areas.
  • Working with field experts to validate assumptions or conduct targeted assessments.
  • Tracking metrics such as land disturbance, water dependency, and impacts on specific habitats.
  • Creating a long-term improvement plan that links biodiversity outcomes to operational decisions.

Once companies begin collecting and organizing this information, they often discover new opportunities to reduce risks, improve community relationships, and strengthen environmental protection efforts.

3. Forward-Looking Metrics: Turning Goals Into Actionable Scenarios

Setting ESG targets is now standard practice, but reporting under ESRS requires much more than high-level commitments. Companies must provide future projections, scenario-based analyses, and evidence-backed pathways to reach their goals. Many organizations struggle here because their current systems were built to track historical data, not future outcomes.

Gap number three appears when teams realize that sustainability goals are not directly connected to financial planning, risk management, or operational decision-making. As a result, targets exist in presentations but lack the internal data structure needed to show how they will be achieved.

To build credible forward-looking metrics, companies should:

  • Translate long-term sustainability goals into measurable, annual milestones.
  • Create scenario models that account for policy changes, climate risks, and market pressures.
  • Connect ESG targets to budgets, capital allocation, and executive decision-making.
  • Make assumptions transparent so progress can be evaluated year over year.
  • Use digital tools that combine operational, financial, and environmental data into one view.

When forward-looking metrics are built correctly, they shift a company from reactive reporting to proactive planning. Leaders gain a clear understanding of what it takes to reach their targets and can make informed decisions based on verified insights.

4. Value Chain Social Data: Going Beyond Tier 1 Suppliers

Social data is often the most difficult category to collect because it requires visibility into labor practices, human rights risks, and working conditions across the entire value chain. Most companies only have structured information for their Tier 1 suppliers. ESRS standards require a deeper look into upstream and downstream activities, something very few teams are prepared for.

The complexity increases when suppliers operate in regions with limited transparency or when subcontracting layers make it difficult to trace data back to its original source. Since ESRS focuses heavily on impacts, risks, and outcomes, organizations must show how people are affected throughout the value chain, not just within direct operations.

To close this data gap, companies can:

  • Use risk-based mapping to identify which parts of the value chain require deeper social assessments.
  • Partner with suppliers to create standardized reporting processes.
  • Develop questionnaires and verification steps tailored to labor, safety, and human rights indicators.
  • Leverage third-party assessments or platforms that help aggregate data from multiple regions.
  • Establish escalation and remediation systems when potential issues are detected.

Expanding visibility beyond Tier 1 lets companies strengthen their social impact data while building more resilient and ethical supply chains.

5. Data Governance: Creating a Single Source of Truth

5. Data Governance: Creating a Single Source of Truth

Even when the right data exists, it often lives in multiple spreadsheets, disconnected systems, or personal files. This creates inconsistencies and increases the risk of errors, duplications, and non-compliant reporting. Without strong data governance, any ESG program will struggle to scale.

The most successful organizations treat ESG data with the same level of rigor as financial data. This means creating a structured governance model that defines how data is captured, validated, approved, and audited. A reliable data foundation is essential for CSRD readiness.

A strong ESG data governance framework includes:

  • Clear roles and responsibilities for everyone involved in data collection.
  • Standardized definitions and calculation methods across all departments.
  • Validation rules to detect errors or missing information early.
  • Secure systems that track data lineage and maintain audit trails.
  • Automated workflows that reduce manual work and eliminate spreadsheet risk.

Once governance is strengthened, companies gain confidence that their ESG data is complete, accurate, and ready for assurance. This transforms reporting from a time-consuming exercise into a strategic capability.

Building CSRD-Ready Data Foundations With VECTRA

Closing ESG data gaps is possible, but it requires more than short-term fixes or temporary spreadsheets. Companies need systems, frameworks, and clear processes that organize data at the source and make it reliable enough for external assurance.

At VECTRA, we help organizations build CSRD-ready data structures that turn fragmented information into verified, decision-ready insights. Our approach focuses on simplifying complexity, strengthening governance, and ensuring that each of the five major data gaps is addressed with practical, scalable solutions.

When the right foundations are built today, companies gain the assurance, speed, and clarity they need to meet ESRS requirements with confidence. Partner now with VECTRA.