- The digital sector's material ESG issues: energy and data centers, e-waste, a large Scope 3, talent and data ethics.
- Which ESRS apply is decided by the double materiality analysis — climate (E1) is almost always material.
- Scope depends on the post-Omnibus thresholds (more than 1,000 employees and €450M net turnover); many scale-ups are out but solicited via the value chain.
- Reliable measurement of digital-specific data (energy, hardware lifecycle) is the main challenge.
The CSRD and the digital sector
The CSRD applies across sectors, but each has a specific ESG profile. For digital and tech companies, impacts concentrate on energy, hardware and people. Whether a company is in scope depends on the post-Omnibus thresholds; smaller players are often solicited indirectly through their clients' value chains.
Material ESG issues in digital
Typical material topics: energy consumption of data centers and cloud, e-waste and hardware lifecycle, a large and complex Scope 3, talent attraction and working conditions, and governance issues such as data ethics and cybersecurity. The double materiality analysis determines which are reported.
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Which ESRS to report
Beyond the cross-cutting standards, the ESRS selected follow materiality: often E1 (climate), E5 (resources and circular economy, for hardware), S1 (own workforce) and G1 (business conduct). Choosing the right indicators is where digital specifics show up.
Reporting challenges specific to digital
The hard part is measuring digital-specific data: energy attributable to cloud usage, hardware lifecycle and e-waste, and a Scope 3 spread across suppliers and users. Centralizing this data and preparing it for audit is where a structured approach pays off — the same rigor as any CSRD reporting, supported by the right reporting tooling.
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CSRD in digital — Key Takeaways
| Key point | Explanation |
|---|---|
| Material issues | Energy/data centers, e-waste, Scope 3, talent, data ethics |
| Scope | More than 1,000 employees and €450M net turnover (post-Omnibus) |
| ESRS | Often E1, E5, S1, G1 — selected via double materiality |
| Challenge | Measuring digital-specific data (energy, hardware, Scope 3) |
