Pioneering sustainability reporting: our frontline journey with early reporters

At PwC, we’ve partnered with early reporters through this complex and evolving landscape. What’s emerging is clear: success in sustainability reporting requires more than technical compliance. It demands cohesive governance, enterprise-wide ownership, strategic assessments, and robust, scalable data systems. This article distills the most critical lessons from the frontline: what’s working, what’s holding organisations back, and how leadership can steer the path forward.

1. Governance: the cornerstone of trustworthy reporting

Lesson 1: Elevate oversight - embed strong governance from the outset

Sustainability reporting isn’t just a regulatory exercise; it’s a litmus test for effective governance. Strong oversight must go beyond reviewing metrics. It must enable cross-functional validation, rigorous interpretation of ambiguous requirements, and transparent documentation of key judgments.

What works: Leading firms have established sustainability reporting specific working groups that include Finance, Risk, Legal, HR, Sustainability, and Operations. These groups act as decision-making hubs, supporting consistent approaches and accelerating alignment. Where possible, companies leverage existing structures - like ESG Disclosure Committees - to formalise reviews and approvals.

Leadership tip: Create cross-functional governance forums with defined charters, senior sponsorship, and clear escalation pathways. Document decisions thoroughly - including rationale and stakeholder inputs - to ensure audit trail integrity and assurance readiness.

Lesson 2: Start smart - align teams before the clock starts

One of the most persistent challenges to timely reporting is role ambiguity across functions, especially for cross-cutting disclosures, such as Scope 3 emissions, where input from multiple functions are required or new disclosure requirements, such as workforce data, that sit outside traditional reporting domains. Functions are hesitant to take the lead due to unclear roles as well as resource constraints and concerns over taking accountability, leading to delays, internal friction, and missed deadlines.

What works: Successful organisations proactively map responsibilities at the start of the cycle, engage teams in co-developing timelines, and assign executive sponsors to drive momentum.

Leadership tip: Establish disclosure ownership early and secure senior accountability. Communicate expectations clearly and confirm alignment before reporting kicks off. Build contingency into plans to account for inevitable surprises.

Lesson 3: Strengthen accountability - distribute ownership across the enterprise

Finance teams are typically the operational lead for sustainability regulatory reporting, but they can’t do it alone. With disclosures spanning emissions, diversity, human rights, remuneration, and more, ownership must be decentralised and embedded across the business to promote expertise-driven reporting, reduce bottlenecks, and enable faster, more resilient processes. 

What works: High-performing companies allocate reporting responsibilities to the teams closest to the data, e.g. HR owns workforce metrics, Procurement manages supply chain data, and Risk handles sustainability-related risks. This promotes accuracy, speeds up the process, and ensures the right expertise is applied.

Leadership tip: Map the reporting workflow and clarify roles and dependencies. Upskill teams where needed, or augment capacity with external support. The shift from a “compliance” mindset to shared accountability is a strategic inflection point.

Lesson 4: Involve Legal early - mitigate disclosure risks proactively

Many sustainability regulations, for instance the CSRD, cover sensitive topics - from political contributions to regulatory penalties. Legal teams are crucial to ensure disclosures don’t expose the organisation to reputational or legal risk. However, Legal is often involved too late in the process, triggering costly rewrites and delays.

What works: Proactive organisations embed Legal into governance forums from day one. They participate in drafting, interpretive discussions, and reviews of high-risk disclosures.

Leadership tip: Include Legal in working groups and narrative drafting sessions. Ensure they review disclosures throughout the process - not just at the end. This enables defensibility, speeds up approvals, and minimises surprises.

2. Materiality assessment: scoping what really matters

Lesson 5: Define the value chain early to sharpen your Materiality Assessment

The Materiality Assessment  is the heart of many sustainability reporting regulations. But many organisations make the mistake of diving in before fully scoping their value chain. This leads to gaps - such as misidentifying which workers belong to S1 – Own Workforce versus S2 – Value Chain Workers or overlooking investment portfolio exposures - which force teams to redo significant parts of the assessment.

What works: Top performers start with a thorough mapping of both upstream and downstream value chain activities. They segment client and supplier categories to anticipate material impacts, risks, and opportunities, and clarify boundaries between their own workforce and value chain workers.

Leadership tip: Treat value chain scoping as a strategic exercise. Involve key business units early such as Sustainability, Finance, Risk and Legal and prioritise areas with the greatest potential impact. Getting this right improves accuracy and significantly reduces rework down the line.

Lesson 6: Engage assurance providers early to minimise surprises

Assurance providers are valuable partners in shaping credible, assurance-ready sustainability disclosures. Their input on emission methodologies, scoping, and materiality judgments can highlight issues before they become problems. 

What works: Leading organisations involve assurance teams at key milestones. They use pre-assurance reviews to challenge assumptions and build confidence in their reporting approach.

Leadership tip: Schedule early touchpoints with assurance providers to test critical decisions. Use their input to strengthen methodologies but balance this with internal judgment and risk tolerance. Not all feedback requires action - recognising the interpretive flexibility within sustainability reporting regulations.

3. Implementation: from reporting to real-world results

Lesson 7: Close data gaps - move beyond estimates

Estimates are currently widespread - particularly in emissions and energy data, where Q4 figures are often unavailable within disclosure timelines. As a result, companies frequently default to estimation methods such as prior-year figures or taking averages across previous Q4 periods. Overreliance on estimates, proxies, and extrapolations undermines trust.

What works: Front-runners are investing in smarter, agile and scalable data infrastructure that automate collection from diverse systems with built in robust controls. 

Leadership tip: Explore AI and automation solutions that enable near real-time data collection from fragmented sources, especially for high-impact metrics like emissions and energy. Machine learning can also enhance estimation accuracy where data gaps persist, producing tailored, dynamic inputs rather than static proxies. 

Lesson 8: Automate manual processes to ensure scalability

Manual data collection may have sufficed in early reporting cycles, but it’s no match for the complexity and frequency of incoming sustainability reporting regulations. As new disclosure requirements emerge and reporting expectations evolve, without automation, reporting becomes a drain on resources and a source of avoidable errors. 

What works: High-performing firms are transitioning to integrated ESG data platforms that unify HR, finance, operations, and environmental systems. This supports end-to-end traceability and efficient audit processes.

Leadership tip: Establish a centralised platform that integrates functional data in a consistent and accessible format and scales with evolving requirements. Build a roadmap to automate routine data collection and embed automated controls to enhance data integrity. Over time, automation will not only streamline compliance but also unlock broader business insights and reporting resilience. 

Lesson 9: Optimise your toolkit - blend external solutions with in-house systems

A hybrid approach is emerging as the most effective path - third-party platforms for structured disclosures, paired with internal tools for niche processes such as workflow management or attestation tracking.

What works: Organisations that succeed take a deliberate, use-case-driven approach to tool selection. They define architecture upfront, assess interoperability, and avoid duplicative systems.

Leadership tip: Design a technology roadmap aligned to your strategic goals. Prioritise integration across platforms and establish clear ownership of each tool’s function. Ensure the technology stack is future-proof and aligned with IT and data govern

4. Looking ahead: rethinking strategy before scaling

The CSRD timeline extensions and the forthcoming ISSB requirements create a window of opportunity. Rather than pause, leading organisations are using this time to reflect, recalibrate, and reinforce their foundations.

Key strategic moves include:

• Reassessing risk appetite: Determining how bold to be on interpretive disclosures and data completeness.
• Scaling internal capability: Upskilling teams and embedding sustainability in day-to-day decision-making.
• Integrating systems: Moving from fragmented spreadsheets to unified platforms.
• Strengthening stakeholder engagement: Aligning disclosures with investor expectations and regulatory scrutiny.