As the sustainability reporting rapidly becoming a reality for organizations worldwide, one of the most frequent questions we hear is simple: Where to start concretely?
For many boards of directors and finance teams, sustainability reporting can seem new, complex, and particularly resource-intensive. Yet, even as regulatory requirements evolve rapidly, this undertaking does not need to be insurmountable, provided it is approached in a structured and pragmatic manner.
Step 1: Conduct an inventory
The first and most important step is to understand where your organization currently stands. Sustainability reporting is rarely a blank slate exercise. Most organizations already address certain aspects of governance, strategy, risk management, metrics, and objectives – either explicitly or implicitly.
An inventory must assess:
- The risks and opportunities related to sustainability that you already take into account in your risk management processes and strategy (for example, environmental, social, and governance topics relevant to your business); ;
- The way your board of directors already considers sustainability-related risks and opportunities, as well as stakeholder expectations, in its oversight and decision-making; ;
- The data already collected; ;
- The level of knowledge and experience, both at the management and board of directors level.
This exercise provides a clear view of the current maturity level and highlights the gaps to be addressed before reporting begins. For many organizations, this first assessment also shows that the challenge is not the lack of actions, but the lack of structure—particularly in how data is collected and managed.
Step 2: Determine your level of ambition for best practices
Sustainability reporting standards largely require organizations to disclose what they do, rather than mandate what they must do. This creates a wide spectrum between minimal compliance and the adoption of best practices.
Determining where your organization wants to position itself on this spectrum is a strategic board-level discussion. Sustainability reports are public documents that will be reviewed by a wide range of stakeholders, including investors, customers, suppliers, employees, and regulators.
The chosen positioning, whether focused on compliance or more ambitious, will directly influence the scope, complexity, and resources required for your sustainability reporting project. The earlier this decision is made, the more effectively the project can be designed.
Increasingly, this decision is influenced not only by regulatory requirements but also by commercial considerations such as access to financing, supply chain expectations, and customer demands.
Step 3: Focus on the Minimum Project Requirements
Regardless of your organization's ambition level for best practices, four fundamental projects will need to be implemented as part of your sustainability reporting process.
Evaluation of Sustainability Materiality Topics (Risks, Opportunities, and Impacts)
This is the foundation of all sustainability-related disclosures. Your sustainability report should be structured around sustainability topics that are reasonably likely to have a material impact on your organization, and, where relevant, the impacts your organization has on people and the environment.
An essential project at the outset is to identify and prioritize these material topics through a structured process, involving people from different company departments and taking into account stakeholder expectations.
Implement a sustainability data and indicators system
Sustainability reporting often requires the implementation or expansion of data collection systems across several themes (e.g., workforce, health and safety, supply chain, governance, resource use, and, where relevant, greenhouse gas emissions).
Even when the data already exists, it is often not collected with a level of control suitable for reporting requirements. Starting early allows for validating definitions, testing data quality, identifying gaps, and adjusting processes before reporting deadlines.
In many cases, organizations also examine how digital tools or platforms can support this process, facilitating data centralization, the application of consistent definitions, and the creation of the necessary audit trail for reporting and assurance.
Without it, sustainability reporting can quickly become manual, fragmented, and difficult to maintain as requirements evolve.
Prospective analysis and resilience planning
Many sustainability reporting frameworks, as well as stakeholder expectations, ask organizations to explain how sustainability-related risks and opportunities are integrated into their strategy, as well as the level of resilience of their business to different plausible scenarios.
This may include scenario analyses, sensitivity tests, or other forward-looking assessments.
Often, these forward-looking analyses, such as scenario analyses, do not need to be entirely redone each year, but can be updated according to your organization's strategic planning cycle (often every 3 to 5 years) and presented consistently each reporting period.
So, even though your reporting obligations won't come into effect for a few years, it may be relevant to start planning for this project now.
Audit preparation
Much sustainability information is subject to assurance, and expectations for verification are increasing over time.
Clear documentation of assumptions, estimates, and judgments is essential. Building audit-ready documentation from day one is significantly simpler than trying to reconstruct it later.
It is also important to retain supporting documents to substantiate your positions, keeping in mind that auditor information requests in the context of sustainability reporting will likely be broader and less standardized than those you are accustomed to in financial statement audits, as sustainability reporting practices evolve.
Why start now?
It will be extremely difficult to implement sustainability reporting retroactively. Data collection systems, processes, and mechanisms must be operational during the reporting period itself to ensure a smooth process.
Starting early also allows organizations to better manage competing demands, as reporting expectations continue to evolve and many organizations face significant transformations in finance, risk management, and governance functions.
It is also important to note that sustainability reporting is increasingly driven not only by regulation, but also by investor expectations, financing requirements, and broader stakeholder demands in many jurisdictions.
Executives and professionals may have personal obligations regarding the preparation and approval of publications, and while many regulators have indicated they will take a pragmatic approach during transitional periods, failing to engage with these requirements presents a real risk.
To remember
Sustainability reporting is a journey, not a one-off exercise.
Organizations that take a structured approach—starting with a baseline assessment, quickly defining their ambition level, and investing in the four foundational projects—will be much better prepared to meet their obligations with confidence and efficiency.
The message is clear: whether you're just starting out or are already committed to this path, the time to act is now.
