Why Your CSRD Data Doesn’t Match Industry Benchmarks
For many small and growing businesses (SMEs) preparing for their first sustainability report, the numbers often don’t seem to “fit” with industry averages. Energy use appears higher, carbon intensity seems off, or waste recycling rates look too low compared to benchmarks. It can feel discouraging — but in most cases, these mismatches say more about data context than poor performance.
The Corporate Sustainability Reporting Directive (CSRD) and the voluntary VSME Standard both stress comparability and relevance. Yet “comparable” doesn’t mean identical — especially when your company’s size, geography, and operations differ from the large firms used in most benchmark datasets.
This article explains the most common reasons your CSRD data might not align with benchmarks, and how to interpret and adjust your results without losing confidence in your reporting.
1. Industry Benchmarks Often Reflect Large Companies
Most published sustainability benchmarks draw from large or listed enterprises that already report under the full European Sustainability Reporting Standards (ESRS). These firms usually have economies of scale, centralised energy management, and advanced measurement tools.
By contrast, SMEs often operate across multiple small sites, rent facilities, or depend on local suppliers — all factors that make data collection less precise. This doesn’t make your data “wrong”; it just reflects a different operational reality.
Tip: When benchmarking, compare with similar-sized peers or suppliers instead of global leaders. The VSME Standard (B3–B7) recognises this proportional approach and allows simplified estimates when exact data are unavailable.
2. Different Measurement Boundaries
Benchmark reports may include data from entire corporate groups, covering subsidiaries and supply chains. Your SME’s report, however, likely focuses on direct operations only (Scopes 1 and 2).
Even within the same industry, boundaries matter: does the benchmark include logistics? Outsourced production? Office-only operations? If not aligned, comparisons will naturally diverge.
Action Step: Clearly state your reporting boundaries under B1 – Basis for Preparation in your sustainability report. Transparency about scope improves credibility, even if numbers differ.
3. Data Estimation Methods Vary
Under the CSRD, sustainability data must be “faithful, comparable, understandable and verifiable.” Yet for many SMEs, energy or water data may come from invoices or building averages — not precise metering. Benchmarks often rely on automated sensors and full-year datasets.
Small data gaps can create large proportional swings when divided by turnover or headcount. Documenting your estimation method (for example, using monthly bills instead of continuous monitoring) helps explain the variation.
4. Sector Diversity and Local Context
Within one industry, conditions can vary sharply between countries. A bakery in Denmark will have very different energy intensity than one in Italy, due to climate and grid mix. Benchmarks rarely adjust for such regional differences, which can make your figures appear “out of line.”
Best Practice: Add context in your commentary — note local energy sources, water scarcity, or building efficiency. The CSRD encourages qualitative disclosures that explain numerical results.
5. Benchmarks Change Faster Than You Think
CSRD-driven transparency is reshaping European data quality. As more SMEs start reporting, benchmark values will evolve quickly. Early discrepancies are expected; they often signal that your company is among the first to publish high-quality, transparent data.
The goal is continuous improvement, not perfection. What matters is year-on-year progress and clarity on how you collect and interpret your figures.
Frequently Asked Questions
Why do my emissions look higher than the benchmark?
Benchmarks often use national averages or data from large corporations with renewable contracts. If your business rents space or uses mixed energy sources, your emissions per euro of turnover will appear higher. Over time, switching to renewable electricity or improving efficiency will narrow the gap.
How can I improve the accuracy of my CSRD data?
Start with the basics: collect consistent monthly energy, waste, and water data directly from invoices or meters. Use the VSME Basic Module’s structure (B3–B7) to standardise metrics. Automation can help, but accuracy mainly comes from regular collection and clear documentation.
Are benchmarks mandatory for CSRD compliance?
No. The CSRD requires you to report faithfully and transparently — not to match or outperform benchmarks. Benchmarks are useful for internal goals or supplier comparison, not for compliance scoring.
What’s the best way to explain data differences to stakeholders?
Be upfront. Include a short note in your report explaining estimation methods, operational scope, and local context. Readers — especially banks and partners — value transparency over artificially “perfect” numbers.
Key Terms
- CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
- VSME: Voluntary Standard for non-listed micro, small and medium-sized undertakings
- ESRS: European Sustainability Reporting Standards
- Benchmarking: Comparing your sustainability data to peers or industry averages
- Scope 1/2/3: Categories of greenhouse gas emissions (direct, energy-related, and value-chain)
Conclusion: Focus on Progress, Not Perfection
If your first CSRD or VSME report shows data that seem “off,” you’re not failing — you’re learning. Sustainability reporting is a journey of refinement. The key is consistency, transparency, and a commitment to improve data quality each year.
Over time, as SMEs across Europe publish more accurate data, the benchmarks themselves will become more meaningful — built not just for large corporations, but for businesses like yours.