What CSRD actually requires of your energy data collection

The Omnibus package entered into force this spring and sharply lowered the threshold for which companies fall under CSRD. But for the large, listed property companies already reporting under the directive, nothing has changed on the energy side: the requirements for verifiable, traceable energy data in ESRS E1 remain in place, while the relief applies elsewhere in the report. The question is whether your energy data collection actually holds up to that scrutiny.

Omnibus doesn’t simplify energy data

Omnibus narrowed which companies fall under CSRD, and eased the requirements in some areas for those already reporting. The Wave 1 companies, those already obliged to report under the old NFRD directive and in practice large listed companies and financial institutions, continue reporting for financial years 2025 and 2026, regardless of whether the new, higher thresholds (1,000 employees and €450 million in turnover) would have exempted them as new entrants today. Some member states may also choose to exempt Wave 1 companies that now fall below the new thresholds during this transition period, though this varies by country. From financial year 2027, the new thresholds apply in full, and that’s when many property companies risk falling out of the requirement altogether. The directive can also apply to non-EU companies with sufficient EU turnover, so international owners of European property portfolios shouldn’t assume it doesn’t concern them.

The relief, the so-called “quick fix” rules, applies specifically to ESRS E4 (biodiversity) and S2–S4 (social areas). E1, the standard for climate and energy, isn’t on that list. The energy data is therefore just as scrutinised as before Omnibus, whatever the simplification debate might have suggested.

ESRS E1 requires granular detail

E1 requires, among other things, disclosure of energy consumption by energy carrier, split between renewable and non-renewable, and emissions from purchased electricity, district heating and district cooling under both a location-based method (the grid’s energy mix) and a market-based method (your actual electricity contracts). ESRS E1 requires granular detail rather than an approximate annual total: which meter point contributed what, over which period, and where each value came from.

What the auditor actually asks for

An independent auditor must review the sustainability statement, with limited assurance as the baseline. In practice, this means the auditor doesn’t recalculate every figure from scratch, but tests whether the information is plausible, consistent, and traceable back to its source. Traceability tends to be the bottleneck: can you show where a specific energy reading came from, when it was collected, and what happened if it needed adjusting afterwards? If the answer lives in someone’s memory or a spreadsheet without version history, that becomes a problem in the assurance process, however correct the number actually is.

Build traceability into the collection, not the report

You can’t solve traceability retroactively by writing a good methodology section in the report, if the data collection itself never logged where each value came from.

At Metry, every collected reading is logged with its source and timestamp from the start, regardless of which utility provider or meter it comes from. You can always trace where a value was retrieved from and when it was received, and readings that fall outside expected ranges are flagged for review through a multi-step validation process before they’re saved, rather than sliding straight into your reporting. It doesn’t solve the whole CSRD report, but it solves the part of the assurance process that’s otherwise hardest to prove after the fact: that every figure can actually be accounted for.

Getting ready to prepare your energy data for the next assurance review? Get in touch, and we’ll go through what your current collection looks like from a traceability perspective.