Common ESRS Reporting Mistakes: 25 Problems That Undermine Compliance and Assurance

Technical status. This article uses the revised ESRS adopted by the Commission on 3 July 2026 as the target requirement architecture, while recognising that the amending delegated regulation was not yet in force until publication in the Official Journal. It also draws on EFRAG’s 2023 implementation guidance where the concepts remain useful; EFRAG states that no implementation guidance had yet been issued for the revised 2026 ESRS. ESMA’s 2025 enforcement reporting is used as evidence of observed reporting weaknesses, not as a complete list of compliance requirements.

Educational material. It does not replace the applicable delegated act, national law, legal advice, professional judgement or an assurance conclusion.

Figure 1. The 25 mistakes mapped across scope, materiality, disclosure, data and publication. Original London Reporting Academy practitioner visual.

Symptom. The sustainability statement copies the financial consolidation list without testing entity-specific, branch, issuer, exemption or value-chain implications.

Why it matters. A technically polished report may be prepared for the wrong undertaking or omit entities relevant to material impacts and metrics.

Fix. Prepare a legal-scope and reporting-boundary memorandum before the disclosure matrix. Reconcile legal entities, financial consolidation and metric-specific boundaries.

Evidence of correction. Approved entity map, legal conclusion, consolidation reconciliation and boundary changes log.

Symptom. Narrative disclosures and metrics refer only to consolidated subsidiaries, while upstream and downstream relationships are absent.

Why it matters. Material impacts, risks and opportunities can arise through products, suppliers, customers, workers and communities outside the consolidated group.

Fix. Build a boundary map that distinguishes the reporting undertaking, own operations, upstream value chain, downstream value chain and metric-specific boundaries.

Evidence of correction. Value-chain map, relationship inventory, boundary rationale and limitations.

Symptom. The project file contains requirements from the 2023 ESRS, quick-fix amendments, draft simplified ESRS and revised 2026 ESRS without a controlled hierarchy.

Why it matters. The report may omit current requirements, retain superseded datapoints or claim compliance with a source not yet legally effective.

Fix. Lock the legal source set for the reporting period. Label each source as current law, adopted-not-effective, draft, implementation guidance or internal practice.

Evidence of correction. Source register, effective-date conclusion, controlled requirement matrix and change log.

Symptom. Revised standards, digital tagging, sector standards or ESRS-40a proposals are described as mandatory before the relevant legal step is complete.

Why it matters. This can mislead management, inflate project scope and create an incorrect compliance statement.

Fix. Use visible status labels in every project and publication document: final and effective, final but not yet effective, adopted pending Official Journal publication, exposure draft, proposal or practice.

Evidence of correction. Status banner, dated source reference and update trigger.

Symptom. The report says “included in the parent report” but does not evidence inclusion, assurance, language, links, publication or listing restrictions.

Why it matters. A subsidiary can remain legally responsible even when a parent publishes sustainability information.

Fix. Convert the exemption into a condition-by-condition evidence checklist and reperform it annually.

Evidence of correction. Parent report, assurance opinion, inclusion map, required links, exemption statement and legal sign-off.

Symptom. The statement reproduces a full datapoint list, including immaterial information, “just to be safe”.

Why it matters. Important information becomes harder to find, internal inconsistencies multiply and assurance effort increases.

Fix. Apply the ESRS materiality and material-information filters. Record why information is included, omitted, not applicable or disclosed voluntarily.

Evidence of correction. Datapoint decision register and reviewer challenge of material information.

Symptom. Stakeholders score topics in a questionnaire, and average scores become the materiality conclusion.

Why it matters. Stakeholder views are evidence inputs, not a substitute for impact severity, likelihood, dependencies and financial analysis.

Fix. Combine operational evidence, due diligence, complaints, incidents, scientific and sector inputs, stakeholder views and finance analysis.

Evidence of correction. Evidence inventory, scoring methodology, qualitative overrides and governance approval.

Symptom. One matrix combines external impact and financial effect into a single weighted score.

Why it matters. An impact can be material without a demonstrated financial effect, and a risk can be financially material without the same external-impact profile.

Fix. Apply distinct impact and financial tests, then consolidate the conclusions at the sustainability-matter level.

Evidence of correction. Separate assessment records and a documented aggregation rule.

Symptom. The methodology excludes suppliers, customers or product use until precise data can be collected.

Why it matters. Lack of primary data does not prove that value-chain impacts or risks are immaterial.

Fix. Use reasonable and supportable information, screening, proxies, sector evidence and estimates; disclose limitations and improvement plans.

Evidence of correction. Value-chain screening, source hierarchy, estimate register and data-improvement roadmap.

Symptom. The same code of conduct is cited for climate, biodiversity, workers, communities and consumers without explaining scope or relevance.

Why it matters. Readers cannot see how the undertaking addresses the identified material IRO.

Fix. Link each policy to the material matter, affected population or environmental issue, scope, owner, approval, commitments and monitoring process.

Evidence of correction. Approved policy, applicability map, governance record and disclosure cross-reference.

Symptom. Training, meetings and audits are listed as actions, but the report does not state which impact or risk they address or what changed.

Why it matters. Activity volume is not evidence of management effectiveness.

Fix. Describe the intended outcome, coverage, resources, implementation status, time horizon and result indicators.

Evidence of correction. Action plan, budget/resource record, implementation evidence and outcome monitoring.

Symptom. The report states “reduce emissions by 30%” or “improve diversity” without a defined baseline, perimeter, unit or target year.

Why it matters. Progress cannot be measured or compared, and changes in scope can produce misleading achievement claims.

Fix. Record metric definition, baseline, boundary, methodology, target level, horizon, milestones, assumptions and approval.

Evidence of correction. Target register, baseline calculation and change-control record.

Symptom. The report says a policy “prevented incidents” because training was completed or a grievance mechanism exists.

Why it matters. Activity and availability do not establish causal effectiveness.

Fix. Use balanced wording and outcome evidence. Distinguish implementation, outputs, observed outcomes and causal conclusions.

Evidence of correction. Outcome trend, evaluation method, limitations and reviewer challenge.

Symptom. Every narrative section presents progress; incidents, missed targets, delayed actions and data limitations are absent.

Why it matters. The statement may not provide a balanced or fair representation of performance and management response.

Fix. Require disclosure owners to report negative developments, open actions, limitations and corrective steps.

Evidence of correction. Issue register, missed-target analysis and approved balanced disclosure.

Symptom. The calculation file contains manual percentages or extrapolations with no source, rationale or sensitivity.

Why it matters. The number cannot be reproduced or challenged and may conceal a boundary gap.

Fix. Maintain an estimate register recording purpose, population, source hierarchy, method, assumptions, alternatives considered, uncertainty and improvement plan.

Evidence of correction. Approved methodology, input evidence, calculation and sensitivity/reasonableness review.

Symptom. A group total combines calendar-year and fiscal-year data, tonnes and kilograms, or controlled entities and selected sites.

Why it matters. The metric may be numerically correct within each source but invalid as an aggregate.

Fix. Enforce a data dictionary and automated or manual validation for period, unit, entity and scaling.

Evidence of correction. Reconciliation, unit conversion file, exception log and reviewer sign-off.

Symptom. Data owners submit files, but no one confirms that all required entities, sites, employees, incidents or transactions are included.

Why it matters. Completeness cannot be demonstrated.

Fix. Reconcile source populations to controlled master data and explain exclusions.

Evidence of correction. Entity/site/employee population reconciliation and completeness attestation.

Symptom. Sustainability teams draft qualitative financial-effects language without linking it to forecasts, impairment, provisions, capex, risk models or management information.

Why it matters. The sustainability statement and financial report can tell different stories about the same risk or opportunity.

Fix. Create an IRO-to-finance bridge with common assumptions, time horizons, responsible finance owner and reconciliation to financial statements or plans.

Evidence of correction. Finance memo, model extracts, assumption comparison and connected-information review.

Symptom. Emission factors, organisational boundaries, incident definitions or survey methods change, but the report presents the trend as directly comparable.

Why it matters. Performance movement may reflect methodology rather than underlying change.

Fix. Apply change control, assess restatement, explain comparability and retain the previous method.

Evidence of correction. Change request, impact analysis, restated comparative or limitation note.

Symptom. The sustainability statement sends readers to an entire policy, website or financial report without an exact location, or references information that does not meet incorporation conditions.

Why it matters. The disclosure becomes difficult to locate and may not be part of the controlled reporting package. ESMA observed that incorporation-by-reference conditions were not always respected.

Fix. Record the precise document, section, page, status and reason incorporation is permitted. Test every link in the final file.

Evidence of correction. Cross-reference map, final-page test and archived referenced document.

Symptom. A row is marked complete when a page number is entered, even though the disclosure is generic or unsupported.

Why it matters. Location confirms navigation, not substantive quality or evidence.

Fix. Separate report location, applicability, evidence, maturity, finding, remediation, retest and final sign-off fields.

Evidence of correction. Controlled matrix with reviewer status and evidence link.

Symptom. The assurance provider first sees methodologies, estimates and boundaries near publication.

Why it matters. Late findings cause rewriting, missing evidence and unresolved scope questions.

Fix. Agree the assurance perimeter, evidence format and high-risk judgements during design; perform dry runs before year end.

Evidence of correction. Pre-assurance request list, walkthrough notes and remediation plan.

Symptom. The preparer changes text and marks the issue closed without reviewer verification.

Why it matters. The correction may not address the root cause, and linked disclosures can remain inconsistent.

Fix. Require correction evidence, independent retest and an explicit closure conclusion.

Evidence of correction. Retest record, reviewer date and linked-issue check.

Symptom. The assurance team, board and web publisher review different files; page references, numbers or source versions change after approval.

Why it matters. The published statement may not be the approved or assured statement.

Fix. Lock the final source file, assign a version, checksum it, re-run cross-reference and metric checks, record approvals and archive the published output.

Evidence of correction. Final-file register, checksum, approval record, publication evidence and post-publication comparison.

Figure 2. A finding is closed only after cause, correction evidence and independent retest. Original London Reporting Academy practitioner visual.

Context. A manufacturing group has a 90% complete disclosure matrix six weeks before publication. A pre-assurance review selects eight rows marked complete.

Findings. Three policy disclosures repeat corporate commitments but do not identify the material impacts they address. A climate target excludes recent acquisitions without explanation. A Scope 3 estimate uses a supplier coverage percentage that is not supported. A biodiversity action describes a site survey but not the management response. Two financial-effects paragraphs use time horizons inconsistent with the risk register.

Correction. The group does not add more narrative. It repairs the control chain: policy-to-IRO mapping, boundary approval, estimate register, action objectives and finance reconciliation. The disclosure matrix fields are changed so that “report location” and “approved” are separate.

Result. The rewritten report is shorter but more specific. The eight rows close only after independent retest. The exercise demonstrates why checklist completion is not the same as reporting readiness.

Myth: “Reporting more information is always safer under ESRS.”

Reality: ESRS reporting requires material, relevant, faithful and understandable information. Reporting every possible datapoint can obscure material matters, create contradictions and weaken controls. A defensible report uses a documented materiality and material-information process, while retaining evidence for inclusion and omission decisions.

Primary connections

Revised ESRS 1 - fair presentation, double materiality, material information, value chain, estimates and presentation.

Revised ESRS 2 - basis of preparation, governance, strategy, IRO process and general requirements for policies, actions, metrics and targets.

Topical ESRS - topic-specific policies, actions, targets, metrics and financial effects.

ESMA enforcement priorities and 2025 enforcement report - observed materiality, structure, incorporation and connectivity issues.

Next practical materials

ESRS Gap Assessment: How to Compare Your Current Report with Revised Requirements.

ESRS Data Governance and Internal Controls: From Datapoint Owners to Assurance Evidence.

ESRS Limited Assurance Readiness: Evidence, Controls and Common Findings.

ESRS Compliance Checklist and Free Disclosure Matrix: What to Complete Before Publication.