How Long Do I Need to Keep CSRD Records?

Introduction

One of the practical but often overlooked questions about CSRD reporting is: how long should you keep all the supporting documents and data?

The Corporate Sustainability Reporting Directive (EU 2022/2464) and the related European Sustainability Reporting Standards (ESRS) don’t specify an exact number of years for record retention. Instead, they expect companies to maintain accessible, auditable evidence for as long as it is relevant for assurance, verification, and stakeholder review.

In practice, most companies — including SMEs — apply the same retention period as financial records, typically six to ten years, depending on national law.

This guide explains how long you should retain CSRD data, what types of records to keep, and how to manage your sustainability documentation efficiently.

1. The Legal Context for Record Retention

While CSRD itself doesn’t set a fixed retention timeline, Article 19a and 29a of the Directive require that:

• Sustainability information must be verifiable and auditable; and
• Companies must provide evidence to support the data disclosed.

Therefore, you need to keep records for as long as they may be required for audit, assurance, or regulatory review.

In most EU countries, this aligns with financial reporting retention laws:

Following your financial record policy for sustainability data ensures compliance and consistency.

2. What Counts as “CSRD Records”

For CSRD and VSME Standard reporting, records include any data, document, or system entry that supports what you disclose in your sustainability report.

Typical CSRD record types:

• Data sources: invoices, meter readings, waste manifests, HR files, supplier declarations.
• Calculation files: spreadsheets, emission factor references, estimation methods.
• Internal communication: data submission emails, review notes, validation forms.
• Policies and governance records: sustainability strategy, double materiality assessments, board approvals.
• Assurance documents: auditor requests, working papers, review findings.

Essentially, if it contributes to your reported numbers or qualitative disclosures, it’s part of your CSRD record.

3. Recommended Retention Periods for CSRD Data

If your company operates in multiple EU countries, apply the longest applicable retention period for consistency.

4. How to Store CSRD Records Effectively

Retention isn’t just about keeping files — it’s about keeping them organised, accessible, and verifiable.

Best practices for SMEs:

1. Use a central shared drive or ESG software tool to store documents by year and topic (e.g. “2025 Energy Data”, “2025 HR Disclosures”).
2. Maintain a data register listing each dataset, owner, and source.
3. Control access — limit editing rights to responsible staff.
4. Back up files securely — either cloud-based or on encrypted local servers.
5. Archive past reports and assurance notes in read-only format.

These habits make assurance easier and protect your company during future data reviews.

5. When to Delete or Archive Old CSRD Data

After the retention period ends, you can delete or anonymise data — unless it’s still relevant for:

• Long-term trend analysis (e.g. energy or GHG reduction targets).
• Stakeholder or regulatory requests.
• Ongoing investigations or assurance reviews.

Personal data (e.g. workforce demographics) should follow GDPR principles — only keep what’s necessary, and anonymise where possible after use.

6. Documentation for SMEs Under the VSME Standard

The VSME Standard (EFRAG, 2024) simplifies record-keeping for smaller businesses:

• You don’t need a formal document management system.
• But you should be able to trace each reported figure to its data source.
• Keep files in digital format (PDF, Excel, screenshots, or supplier declarations).

If you undergo voluntary limited assurance, your verifier will expect traceability for at least the latest reporting year plus previous year comparisons.

Frequently Asked Questions

Do I have to keep CSRD data forever?

No, but keep reports and key supporting data for at least six to ten years, or as required by your national law.

Can I store CSRD data digitally?

Yes — digital storage is fully acceptable, as long as it’s secure, backed up, and accessible for audits.

Do SMEs under VSME have shorter retention periods?

They can apply the same periods as financial records, but proportional storage (fewer documents, simpler systems) is fine.

What if I change software systems?

Export or migrate all CSRD data and metadata before switching tools — especially if assurance evidence is stored in the old system.

Key Terms

• CSRD (Corporate Sustainability Reporting Directive) – EU law requiring sustainability reporting and assurance.
• Record retention – Keeping documentation for a legally defined period.
• VSME Standard – Voluntary SME reporting framework developed by EFRAG.
• Assurance evidence – Proof used by auditors to verify reported information.
• Traceability – Ability to link reported data back to its original source.

Conclusion

There’s no single EU-wide rule for how long to keep CSRD records, but the safest approach is to align with your financial record retention policy — usually six to ten years.

Keep all key sustainability data, calculations, and policies securely stored and traceable for at least that period. This ensures you’re always ready for assurance, regulatory checks, or stakeholder questions — while demonstrating sound governance under CSRD principles.

For more on preparing for assurance and verification, see Who Can Verify My CSRD Report?.

While this guide focuses on record retention, you may also need to identify which Scope 3 categories apply to your business:

This tool will help you understand which emissions categories you need to track, which will inform your record-keeping requirements.