EU Voluntary Standard Implementation Checklist: 60 Questions for the First Reporting Cycle

Figure 1. Branded implementation visual for EU Voluntary Standard Implementation Checklist: 60 Questions for the First Reporting Cycle.

Is the reporting undertaking outside mandatory sustainability reporting under Articles 19a and 29a of the Accounting Directive?

Does the undertaking exceed, on the balance sheet date, an average of 1,000 employees during the preceding financial year?

Is the undertaking part of a group whose reporting basis may change the practical response?

Is the organisation responding as an individual entity, a subsidiary, a parent or a consolidated group?

Has the reporting period been aligned with the financial statements where financial statements are prepared?

Is the request from a CSRD-reporting customer, a bank, an investor, a public tender authority or another requester?

Is the requester seeking information for its sustainability reporting under the Accounting Directive, or for another legal/commercial purpose?

Has the organisation documented whether it is a protected undertaking for this request?

Has the organisation recorded the legal entity, registration details, address, activities and main sites used in the response?

Has the organisation retained the evidence supporting its employee band and reporting basis?

Has management selected Option A - Basic Module only, or Option B - Basic Module plus Comprehensive Module?

Has the selected option been recorded in B1 and repeated consistently in the report, packs and questionnaire responses?

If the Comprehensive Module is used, has the Basic Module been completed first?

Has the organisation avoided mixing Comprehensive datapoints into an Option A compliance statement without explaining the status?

Has the organisation decided whether the report is prepared on an individual or consolidated basis?

Has the organisation identified any subsidiaries included or excluded from the reporting boundary?

Has it explained changes in basis compared with the previous year, if any?

Has it identified which datapoints are essential, if applicable, voluntary or sector-related?

Has it separated report content from restricted evidence and internal calculations?

Has a single version owner approved the module selection and reporting basis?

Has each B1-B11 datapoint been assessed as applicable, not applicable, unavailable, estimated or voluntary?

Has each C1-C9 datapoint been assessed only if the Comprehensive Module is used?

Has the organisation documented why a datapoint is not applicable rather than merely leaving it blank?

Has the organisation identified the boundary for energy, GHG, water, waste and workforce metrics?

Are units, periods and definitions consistent across the report and questionnaire answers?

Has the organisation checked whether B3 energy and GHG data are complete for Scope 1 and location-based Scope 2?

Has it avoided treating Scope 3 or climate targets as mandatory unless the relevant conditions are met?

Has it checked whether sector exposures under C8 are own activities, not merely customer industries?

Has it documented any voluntary above-cap information separately from cap information?

Has the datapoint status been mapped to Annex II where the request concerns the value chain cap?

Does every quantitative datapoint have a named data owner?

Does every narrative disclosure have an accountable content owner?

Is there a source document, system extract, calculation file or policy record behind each response?

Has the organisation recorded the methodology used for estimates?

Has it distinguished unavailable data from estimated data?

Has it identified confidential, trade-secret, personal-data or security-sensitive information before release?

Are approvals retained for policies, future initiatives, targets and public claims?

Have calculations been checked by someone other than the preparer where practicable?

Has evidence been labelled by version, period and disclosure reference?

Has the organisation created an improvement plan for the most important gaps?

Has the organisation decided whether to prepare a public report, restricted counterparty pack, lender pack or all three?

If the report is public, has the organisation reviewed confidentiality and consistency with other public claims?

If the report is restricted, is the access route and permitted audience recorded?

Does the counterparty pack reuse approved answers rather than rewriting them for each request?

Does the lender pack highlight credit-relevant information without changing the underlying facts?

Are cross-references to other documents accessible at the same time and from the same document set?

Is there a response history showing what was released, to whom and when?

Are version numbers included on reports, evidence packs and questionnaire exports?

Has the organisation avoided claiming external assurance, verification or certification unless that is true?

Does the report explain omissions and limitations without hiding material uncertainty?

Has finance reviewed financial, turnover, workforce and boundary consistency?

Has HR reviewed workforce, health and safety, remuneration and training data?

Has operations reviewed energy, emissions, water, waste and site data?

Has legal or management reviewed confidentiality, trade secrets and personal-data issues?

Has the governance owner approved policies, practices and future initiatives wording?

Has a release approver signed off the final version before external sharing?

Has the organisation recorded any voluntary provision of above-cap information?

Has it documented declined, clarified or negotiated requests?

Has it scheduled the next reporting cycle and interim data refresh points?

Has it logged update triggers, including new law, new customer requirements, material changes and data corrections?