How to Handle Multi-Site Reporting for CSRD

Introduction

If your company operates across multiple offices, plants, or warehouses, you may be wondering how to structure your CSRD reporting. Should you report data per site or as a group? How do you ensure consistency between locations?

The Corporate Sustainability Reporting Directive (CSRD) and the VSME Standard (EFRAG 2024) both allow flexibility, as long as your approach is transparent, consistent, and traceable. Whether you have two sites in one country or several across Europe, the key is to define a clear reporting boundary and implement a repeatable data collection process.

This guide outlines practical steps for small and growing businesses (SMEs) to manage multi-site reporting efficiently, from defining scope to consolidating results for your sustainability statement.

1. Define Your Reporting Boundary

Start by deciding which sites are in scope for CSRD or VSME reporting. According to ESRS 1 (General Requirements), all entities under your operational or financial control must be included.

For SMEs, this means:

• Owned or leased sites used for production, logistics, or administration.
• Subsidiaries where you have majority control.
• Permanent facilities within the EU (and, if relevant, key non-EU locations).

Temporary project sites or minor sales offices can often be grouped or estimated to simplify reporting. Always document inclusion and exclusion criteria.

Example disclosure:

“The 2025 sustainability data includes operations in Lyon, Hamburg, and Milan, representing 95% of total energy use. Small sales offices were excluded due to immaterial impact.”

2. Create a Standardised Data Template

Multi-site reporting succeeds when all locations follow the same data collection format. Develop a reporting template covering your key sustainability metrics, aligned with ESRS or VSME modules.

Common sections include:

• Energy use (Scope 1 & 2) – gas, electricity, fuel.
• Waste generation and recycling.
• Water use.
• Workforce metrics – headcount, training hours, gender balance.
• Local initiatives or social programmes.

Each site should fill in the same columns and definitions (e.g. kWh for energy, tonnes for waste) to ensure consistent consolidation later.

For smaller teams, a shared spreadsheet or cloud-based form works well; for larger groups, sustainability software may be more efficient.

3. Assign Local Data Owners

Every site needs a designated data owner — someone responsible for collecting, checking, and submitting sustainability data. Typically:

• The facility manager handles energy, waste, and water data.
• The HR or site admin manages workforce and training metrics.
• A central coordinator reviews submissions for accuracy.

Establish clear reporting deadlines and create a data log for version control. This makes consolidation and future assurance processes far smoother.

For guidance on setting up efficient workflows, see our article on how to integrate CSRD data collection into existing workflows.

4. Consolidate Site-Level Data

Once each site’s data is submitted, aggregate it into a group-level total. Be sure to:

• Use consistent units (e.g. all energy in kWh).
• Verify that totals align with financial or operational data (e.g. energy spend, staff numbers).
• Check for anomalies — unusually high or low figures often indicate entry errors.

If you use estimates for smaller sites, note this in your methodology. The CSRD Directive allows proportional reporting for less material locations, especially for SMEs with limited capacity.

5. Ensure Consistent Data Quality

Quality control is critical in multi-site setups. To ensure reliability:

• Apply the same estimation methods across all sites.
• Review emission factors and benchmarks annually.
• Conduct random data checks or internal audits.
• Keep all supporting evidence (invoices, meter readings, waste manifests).

A simple data review checklist can help catch inconsistencies before consolidation.

For more detail on ensuring reliability, see how accurate CSRD data needs to be.

6. Report at Group Level — with Site Detail if Relevant

For CSRD and VSME reporting, you only need to disclose consolidated totals (e.g. total energy use, total waste). However, including site-level commentary can strengthen transparency — especially if one location drives most impacts.

Example disclosure:

“The Hamburg production site accounted for 72% of total electricity use due to higher machine utilisation. Energy-saving measures implemented there reduced overall consumption by 5%.”

You can include such breakdowns voluntarily to highlight progress or contextual differences between facilities.

7. Use Proportionality for SMEs

Under the VSME Standard, SMEs can simplify multi-site reporting by:

• Grouping similar sites (e.g. regional offices or small workshops).
• Using sampling or averages for immaterial sites.
• Reporting at company level without individual site breakdowns if total impact is minor.

This proportional approach ensures compliance without creating unnecessary administrative burden.

Frequently Asked Questions

Do I need separate CSRD reports for each site?

No. You should publish one consolidated report covering all in-scope operations. However, you may include site-level annexes or tables for transparency.

What if one site is outside the EU?

Include it if it’s under your operational control and relevant to your total impact. Otherwise, disclose the exclusion and explain why it’s immaterial.

Can I estimate smaller sites’ data?

Yes. Use benchmarks, averages, or proportional methods for smaller sites and disclose your estimation approach — fully compliant under both CSRD and VSME.

How do I manage assurance for multiple sites?

Auditors will sample data across key sites, so maintain complete records and consistent templates. Clarity and traceability matter more than complexity.

Key Terms

• Reporting boundary – The organisational scope of entities and sites covered in a sustainability report.
• Consolidation – Combining multiple datasets into one group-level total.
• Proportionality – VSME principle allowing smaller businesses to simplify reporting.
• ESRS – European Sustainability Reporting Standards defining required disclosures under CSRD.
• Limited assurance – Independent verification confirming data plausibility and consistency.

Conclusion

Handling CSRD reporting across multiple sites doesn’t need to be difficult. By defining your boundary, standardising templates, and assigning local data owners, you can build a clear, scalable process that meets both CSRD and VSME expectations.

Consistency, transparency, and proportionality are the keys to success — helping you manage complexity without adding unnecessary workload.

For next steps, use our annual CSRD reporting calendar to schedule your data collection and consolidation activities throughout the year.

To help you organise data collection across all your sites, use our checklist generator to create a standardised checklist:

This tool will help you ensure consistent data collection across all locations and identify any gaps in your reporting process.