Go to content

1. Introduction


1.1 Background

The background of this project arises from the new regulation CSRD
CSRD or Corporate Sustainability Reporting Directive mandates companies to report on their impact of corporate activities on the society and environment, and mandates assurance of the reported data in the integrated report. (European Parliament and Council, 2022)
issued by the European Union. The directive is part of the European Green Deal
The European Green deal is a set of political initiatives initiated by the EU commission. The goal is to reach climate neutrality in 2050. The key goals are Climate neutrality, Circular economy, Clean industries, Healthier environment, more sustainable farming and Climate justice and fairness. (Council, 2024)
. The directive requires companies to comply with more stringent sustainability related disclosure and reporting requirements, than ever before. In this context, companies will face two significant challenges:
  1. The need to comply with new disclosure requirements and datapoints for reporting.
  2. The need for increased levels of ESG data exchange and management
    ESG stands for “Environmental, Social and Governance”, which are factors used to measure the environmental and societal impact of a company’s activities and investments (Danish Business Authorities, ND). In that regard, it has not been common practice for companies now subject to these regulations to share their ESG data with one another, as mandated by CSRD.
    .
The type of mandatory and standardized data sharing between companies required by CSRD has not been common practice, and therefore it represents a new administrative and financial burden for the companies subject to the directive. In addition, the directive introduces numerous new disclosure requirements and datapoints, for which the companies lack both understanding and data. Moreover, as large companies subject to CSRD are required to report on their entire value chain, including suppliers, SMEs will face significant pressure to collect and provide this data, even if they are not directly subject to CSRD. This project is designed to address the challenges that come with the new directive and goals set out in the European Green Deal. The focus is, to map out the business’ needs for sharing climate data efficiently and the associated practical business needs for data management. The project aims to provide specific recommendations to streamline and simplify sustainability reporting and support long-term business growth, by mitigating burdens imposed on companies through regulatory requirements. The project will draw on the experiences gained through current and previous initiatives carried out by the Nordic countries. The Nordic countries have established a common framework through the Nordic Government and Business Program, with a focus on digitalizing reporting and data-sharing practices since 2016. This collaboration has resulted in the development of solutions that facilitate cross-border trade by enabling seamless exchange and integration of electronic documents (eDocuments). This work has resulted in the exchange of eDocuments and the information they contain becoming highly automated and efficient. The term "eDocuments" encompasses a broad range of digital documents that can be exchanged between a supplier and customer, such as electronic Invoices (eInvoices), and electronic Catalogues (eCatalogues). Today, these documents are primarily exchanged between public institutions and suppliers for public entities and are not widely used in B2B scenarios. Moreover, the current eDocuments do not contain much of the information companies need for their CSRD and ESG reporting, particularly for Scope 3 emissions
Scope 3 emissions refer to activities that emits CO2e outside the company’s control, but as a consequence of the company’s activities. These emissions refer to the processes that happens in the early stages of the stages of a “products” life cycle, before it enters the reporting companies supply-chain, but also processes that occurs after the undertaking has sold a product (Barrow, Buckley, Clummis, & Draucker, 2013)
.
As a result, these challenges create a strong demand in the market for standardized climate data and efficient data exchange. With respect to this, the project focuses on how eDocuments can facilitate the exchange of standardized climate data, not only to ensure compliance, but also to push for green data interoperability, leading to increased understanding of climate across supply chains and a better foundation for making lasting and positive changes. The argument is that large international companies without standardized data formats most likely will develop and impose heterogeneous compliance demands on SMEs, which would leave the SMEs with a significant and avoidable administrative burden, and shift resources from focusing on making a positive impact to purely ensuring compliance. The goal of integrating climate data in eDocuments and easing the administrative burdens of managing and exchanging climate data reflects parts of the Nordic Council of Ministers' goal:
“The Nordic Region shall be the most sustainable and integrated region in the world by 2030” (Aagaard, 2019).

1.2 Project Purpose

The purpose of this project is to provide recommendations to how the Nordic countries can reduce the administrative burdens connected with sharing climate data. The aim is to establish a common and interoperable frame for eDocuments in which companies can easily calculate and share their climate impact and thus promote sustainable procurement. The project further aims to integrate climate data into existing digital formats and setups. This includes specifications such as materials, weight, CO2 equivalents
CO2 equivalent (CO2e) refers to a metric used for comparing emissions from different greenhouse gases. Other gases different from Carbon Dioxide (CO2) are converted with what is called “Global-warming potential (GWP)” factors, to CO2e emissions (Eurostat, ND).
(CO2e) emissions etc., of products or services, which is crucial information for the companies to collect in order to be compliant with CSRD and the European Sustainability Reporting Standard’s (ESRS)
The ESRS Standards are sustainability standards developed under the CSRD. They present a structured approach for companies to disclose their sustainability impact on earth and societies. In total, ESRS represents 12 standards, which takes into consideration all aspects of Environmental, Social and Governance (ESG). (EFRAG, ESRS workstreams, 2023)
. The project will therefore build further on the existing Nordic countries’ experiences to implement climate data in eDocuments.

1.3 Key Objectives

As stated, the project aims to investigate how, through a Nordic cross-border collaboration, administrative burdens can be eased, with particular focus on the exchange of climate data for businesses to calculate their climate footprint.
The project included three workshops in the fall of 2024, where the purpose was to develop mockups and identify solutions that can be integrated in the existing digital infrastructures and reach the specific requirements of climate impact calculations.
The summarized objectives in the workshops are:
  • To concentrate on climate related datapoints which are mature and feasible for the current digital setups.
  • To concentrate on how to integrate the climate related datapoints into the relevant eDocuments.
  • To concentrate on how to enable automatic processing and reduce manual tasks.

1.4 Limitations of scope

Considering the extensive content covered by the CSRD/ESRS, there is a need to limit the areas explored in this project. This is done to ensure that the recommendations can be made as specific and actionable as possible.

1.4.1 Inside scope

The project focuses on incorporating the ESRS E1 standard, specifically the disclosure requirements E1-4 and E1-6 and associated datapoints, along with the Greenhouse Gas (GHG) protocol. This is to ensure that the data formats used in the mockups are both compliant with regulations and relevant to broader climate reporting needs. Further, the project will primarily focus on product data, more specifically on category 1, according to the GHG Protocol, “Purchased goods and Services”.

1.4.2 Outside scope

The project will not investigate other sustainability reporting standards and will focus solely on the climate aspect of ESG. Whereas areas within the environmental aspect of ESG with undetermined methodologies, such as biodiversity, has not been considered during this project. Additionally, energy data and transport data has not been considered during the workshops or in the development of the mockups, due to e.g. the Mobility and Transport regulation “exchanges of regulatory Freight Transport Information” (eFTI) will facilitate the aspects of transport of freight (European Commision, ND). Additionally, only CO2e will be used as the emission factor to calculate the climate impact of a product or service. Lastly, national legislation and requirements for digital reporting have not been included.