case study
Optimizing CSRD compliance through a tailored fit-gap analysis
Peter-Jan Roose
Following the completion of a Double Materiality Assessment (DMA), a leading European food manufacturing company needed to ensure that its sustainability reporting aligned with the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD). To bridge the gap between available data and ESRS requirements, a fit-gap analysis was conducted. This assessment provided a structured approach to identifying missing elements, evaluating reporting readiness, and defining a roadmap for full compliance.
Challenge
The main challenge was understanding gaps in data availability: what data was required for full CSRD compliance, what was already available, and what was still missing. Ensuring alignment with ESRS meant identifying specific disclosure requirements and mapping them to existing internal data sources. However, gathering all available data was complex and time-consuming, requiring input from multiple teams across the organization. Engaging these stakeholders and structuring the data for reporting was essential to closing the gaps and preparing for compliance.
By ensuring sustainability disclosures are accurate, complete, and ESRS-aligned, the company strengthens credibility, builds trust, and reduces regulatory risk.
Approach
The fit-gap analysis followed a structured approach to define the necessary data requirements, assess current data availability, and establish a roadmap for compliance.
Step 1: Identifying Reporting Requirements (TO BE Situation)
With the Double Materiality Assessment (DMA) complete, the company had a clear understanding of which ESRS (sub)topics were material for their business. Using the ESRS topic database, these material topics were mapped against the ESRS Disclosure Requirements to determine what specific data points needed to be reported. This step established the TO BE situation: the ideal state where all required data is available for full ESRS compliance.
Step 2: Assessing Current Data Availability (AS IS Situation)
The next step was evaluating the AS IS situation, analyzing which of the required data points were already available within the company’s existing sustainability reporting framework. This assessment helped identify:
Fully available data: Information that was already being tracked and reported in alignment with ESRS requirements.
Partially available data: Data that existed but needed restructuring, additional validation, or more granular tracking.
Missing data: Required disclosures for which no structured data collection was in place.
Step 3: Defining the Data Governance Roadmap
The final step was to create a Data Governance Roadmap, outlining the necessary actions to bridge the gap between the AS IS and TO BE situations. This roadmap included:
Data collection strategy: A plan to gather missing data, including necessary tools and methodologies.
Ownership and accountability: Assigning responsibility to specific departments or individuals for data collection and reporting.
Timelines and implementation milestones: Establishing deadlines for closing data gaps in preparation for CSRD reporting deadlines.
By structuring the transition from current data availability to full ESRS compliance, the roadmap provided a clear, actionable framework to improve data governance and ensure the company was prepared for future reporting obligations.
Impact
The fit-gap analysis provided sustainability value by ensuring the company could accurately measure and report its environmental and social impact. Identifying data gaps improved tracking of emissions, resource use, labor practices, and governance factors, enabling stronger ESG performance management and alignment with regulatory expectations. The roadmap also established a structured approach to ongoing sustainability reporting, ensuring adaptability to future requirements.
Beyond compliance, the analysis delivered business value by revealing data black boxes (areas where information is missing or lacks transparency) hindering informed decision-making. Addressing these gaps allows the company to integrate ESG insights into strategy, enhancing transparency with investors, customers, and stakeholders. By ensuring sustainability disclosures are accurate, complete, and ESRS-aligned, the company strengthens credibility, builds trust, and reduces regulatory risk.
Summary
A European food manufacturer partnered with BrightWolves to align its sustainability reporting with CSRD requirements through a tailored fit-gap analysis.
We mapped ESRS disclosure requirements, assessed current data availability, and designed a roadmap to close data gaps and ensure compliance.
This improved ESG data governance, enhanced transparency, and prepared the company for upcoming reporting deadlines.
Beyond compliance, the project strengthened decision-making by uncovering critical data gaps and embedding ESG insights into business strategy.