CSRD and energy procurement: what your auditor will ask next year.

§ 01What changes — and for whom

The Corporate Sustainability Reporting Directive requires companies that fall within its scope to report on sustainability in the management report in line with European standards, the ESRS, and to have that reporting assured by an external assurance provider — in the Netherlands usually the auditor. [1] [4] That makes the reporting no longer a separate sustainability report, but part of the annual reporting, with comparable requirements for substantiation.

One important caveat: in 2025 the European legislator revised the scope and the timeline, deferring the start for parts of the business sector and adjusting the thresholds. [3] Whether and when your organisation has a reporting obligation is therefore something to check against the current position — this article is about what the standard asks once you fall under it, or once your large clients start asking. Because even if you have no reporting obligation yourself, the question reaches you: clients that do report need data from their chain.

§ 02What ESRS E1 asks about energy

The ESRS E1 climate standard contains data points on an organisation's energy consumption and how that consumption is made up. In short, the standard asks for total energy consumption, the breakdown into fossil and renewable sources, and the substantiation of the renewable component. E1 also asks for greenhouse gas emissions, where energy consumption is a major source of the scope 1 and scope 2 figures. [2]

For energy procurement, three consequences follow from that:

• Every energy flow counts separately. Natural gas for the process, diesel for generators, electricity from the grid, fuel for your own transport — each with its own quantity and its own origin.
• The figures have to reconcile. The reported quantities must be traceable back to invoices, meter readings, delivery notes and certificates. That is what the auditor looks at.

§ 03How the auditor tests it

Assurance on sustainability information works no differently from assurance on financial information: the auditor looks for evidence that the reported figures are accurate and complete. [4] For a claim that "x per cent of our energy consumption was renewable", that means, concretely:

• Existence. Was the energy actually delivered and consumed? Evidence: delivery notes, meter readings, invoices.
• Reconciliation. Do the quantities in the evidence match the quantities in the report? Evidence: a reconciliation per energy flow and per period.
• No double counting. Has the same renewable quantity not been claimed elsewhere as well? Evidence: cancellation of certificates, registration in the national registry or the Union Database. [5]

A supplier's declaration — "we deliver you sustainable fuel" — meets none of these four. It proves no existence, no origin per consignment, no reconciliation and no cancellation. That is why many sustainability claims are toned down in a first round of assurance: not because they are wrong, but because they cannot be substantiated.

§ 04What you need to have in place per energy flow

Translated into a practical checklist — for every energy flow you want to report as renewable:

• The quantity delivered per period, with a delivery note or meter reading.
• The origin: source or production site, feedstock type, and the certification scheme under which the chain was tracked.
• The greenhouse gas characteristics that travel with the consignment, in the unit your report uses.
• The reconciliation between evidence and report: a single overview in which every reported quantity points to a record.

If you log this per delivery, you have an evidence file at the end of the year. If you have to reconstruct it afterwards, you have a problem — and usually a weakened claim.

§ 05What this means for your choice of supplier

The CSRD changes the procurement question. Alongside price and security of supply, the third question becomes: does this supplier deliver the evidence with it, per delivery, in a form my auditor accepts? For electricity that is market standard. For fuels and gas it isn't yet. So ask explicitly for chain-of-custody records, certificate numbers and the option to receive an evidence file per project or period. Suppliers that have no answer to that deliver energy — but not reportable energy.

§ 06How Powercrumbs fits in

The Powercrumbs chain is designed around this question. Every delivery of renewable gas carries an origin marker, and per project or period an evidence file builds up with the quantity delivered, the origin per consignment, the transport and swap log and the metered consumption — the Proof Trail. One item from the checklist above isn't part of it: a certificate cancelled in your name. That arises with injection into the gas grid, and this gas goes straight from source to site. What carries the claim is the physical chain itself. How that file builds up step by step is described in From claim to proof. And how RED III, CSRD and CBAM relate to one another is set out in the regulatory framework.

This article describes the system and is not accountancy or legal advice. For your own reporting obligation and the requirements of your assurance provider, consult the current legislation and your adviser.

§ 07References

• European Union — Directive (EU) 2022/2464 (CSRD) — sustainability reporting obligation, scope, assurance requirement.Regulation · primaryPrimary
• EFRAG — European Sustainability Reporting Standards, in particular ESRS E1 (climate) — data points on energy consumption, energy mix and greenhouse gas emissions.Reporting standard · delegated regulationPrimary
• European Union — 2025 amendments ("stop-the-clock" and the Omnibus package) that change the scope and timeline of the CSRD.Regulation · in fluxPrimary
• Koninklijke NBA / audit firms — guidance on assurance of sustainability information and the evidence requirements for reported data points.Professional body · nlHigh
• European Union — Directive (EU) 2023/2413 (RED III) — the evidence system (mass balance, certification) that a renewable fuel claim rests on.Regulation · primaryPrimary

Full references (titles, dates, links) to follow.

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