Do the materiality assessment before anything else
Double materiality decides your reporting scope. Running it late means collecting data you will not disclose and discovering gaps in data you must. Assess impacts on people and environment alongside financial effects on the business, involve finance and operations rather than sustainability alone, and keep the evidence for how each conclusion was reached — assurance providers will ask.
Translate ESRS data points into named owners
Each applicable data point needs a person, a source system and a cadence. This is where most readiness programmes stall: the requirement is understood in the abstract but nobody is accountable for the number. A simple register of data point, owner, source, frequency and current state turns an intimidating standard into a manageable work list.
- Data point reference and the disclosure it feeds.
- Named owner and their backup.
- Source system or document, and how it is extracted.
- Current state: available, partial, estimated or missing.
Run a gap assessment you can act on
Rate each data point on availability and reliability, then treat the weak ones as findings with corrective actions and dates. Handling gaps as tracked remediation rather than as a spreadsheet colour code means progress is visible and the audit committee can see the trajectory.
Prepare for assurance from day one
Assume every figure will be sampled. That means source documents attached at the point of entry, calculations reproducible without the original author, and a change log explaining restatements. Teams that build this in from the first cycle spend their assurance period answering questions instead of reconstructing evidence.
Where first-time reporters lose the most time
Four recurring patterns: waiting for a perfect Scope 3 methodology before publishing anything, treating value-chain data requests as a procurement exercise rather than a relationship one, running the assessment without finance in the room, and keeping the whole programme in workbooks that only one person can operate.