Do Creative Agencies Need to Report Pollution?
If you run a design studio, marketing firm, or creative agency, you’ve probably looked at the Corporate Sustainability Reporting Directive (CSRD) and wondered:
“Do we need to report on pollution if we don’t produce anything physical?”
The short answer is: ✅ No — for most creative agencies, pollution is “not applicable.” However, you should still acknowledge it clearly in your sustainability disclosure to show that you’ve considered and assessed the topic. For general guidance on office-based businesses, see CSRD for office SMEs and the VSME guide.
Why “Not Applicable” Is the Right Answer for Most Agencies
Under the VSME Standard (Basic Module B4) and CSRD Article 19a, SMEs are expected to report on environmental topics proportionately — meaning only those that are material to your activities and impacts.
“Pollution” under the CSRD refers to emissions to air, water, or soil, such as:
- Greenhouse gases (already reported separately under Energy and GHG in VSME B3)
- Air pollutants (NOₓ, SO₂, VOCs, particulates)
- Water pollutants (chemicals, heavy metals, effluents)
- Soil contamination (fuels, oils, industrial waste)
Since most creative agencies operate in office-based environments, they do not emit or discharge any regulated pollutants. Their environmental footprint is limited to:
- Electricity use for offices and equipment
- Employee commuting or travel
- Digital infrastructure (e.g. cloud servers)
None of these are classified as “pollution” under EU environmental definitions.
What to Write in Your CSRD or VSME Report
You shouldn’t leave the B4 – Pollution section blank. Instead, include a short justification like this:
“The company operates in an office environment and does not generate direct emissions to air, water, or soil. Pollution is therefore not considered material under VSME B4.”
This shows that you’ve reviewed the topic, applied materiality, and are compliant with CSRD expectations — even when reporting “not applicable.”
When Pollution Reporting Does Apply to Creative SMEs
There are a few exceptions where creative or marketing firms may need to include pollution data:
| Situation | Example | Why It Matters |
|---|---|---|
| In-house printing or production | Using solvents, inks, or spray adhesives | May release VOCs (report under VSME B4) |
| Vehicle fleets | Delivery or installation vehicles | Contributes to air emissions (Scope 1) |
| Event production or staging | Use of generators or fuels | Can create temporary local pollution |
If any of these apply, you should disclose qualitative or estimated data under B4 – Pollution and link it to your B3 – Energy and GHG figures.
How to State “Not Applicable” Transparently
| VSME Section | Disclosure | Example |
|---|---|---|
| B3 – Energy and GHG | Electricity and commuting data | 42 MWh, 9.5 tCO₂e |
| B4 – Pollution | Not applicable | Office-based, no pollutant emissions |
| B6 – Water use | Utility invoices | 110 m³/year |
| B7 – Waste | Office recycling | 1.8 tonnes (70% recycled) |
This format keeps your disclosure complete and easy for reviewers, clients, or verifiers to follow.
Why This Still Matters for Creative Agencies
Even though pollution isn’t material, reporting responsibly shows:
- You’ve conducted a double materiality assessment, as required by CSRD.
- You understand which environmental topics are relevant to your business.
- You’re transparent about your limited footprint while still addressing other areas (energy, waste, commuting).
This approach demonstrates professionalism and helps meet supplier sustainability requests from larger CSRD-compliant companies.
Practical Tips for Creative SMEs
- Use the “not applicable” statement whenever pollution doesn’t arise.
- Review annually — if your business adds production or printing capacity, update your assessment.
- Keep focus on energy and waste data — they’re the most material environmental topics for office-based creative firms.
- Combine environmental and social data for a rounded sustainability section.
How It Aligns with CSRD and VSME
| Framework | Topic | Relevance |
|---|---|---|
| VSME B4 | Pollution | “Not applicable” for non-manufacturing SMEs |
| VSME B3 | Energy and GHG | Office electricity and digital footprint |
| CSRD Article 19a | Materiality principle | Disclose only significant environmental impacts |
| ESRS E2 | Pollution | Reference standard for companies with emissions |
The key takeaway: state it, justify it, and move on confidently.
Example: Small Design Agency Disclosure Snapshot
Company: Brightline Studio Ltd Sector: Creative & Marketing Services Size: 20 employees Highlights:
- Energy use: 25 MWh
- GHG emissions: 5.5 tCO₂e
- Pollution: Not applicable (office-based)
- Waste: 1.2 tonnes (80% recycled)
Narrative:
“Brightline Studio operates solely in an office environment. The company generates no emissions to air, water, or soil. Pollution is therefore not material. Efforts focus on reducing energy use, digital emissions, and office waste.”
Key Terms
- CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
- VSME: Voluntary Sustainability Reporting Standard for non-listed SMEs (EFRAG, 2024)
- B4 – Pollution: Section covering emissions to air, water, or soil
- Materiality: Reporting principle that determines whether a topic is significant
- Scope 1 & 2 emissions: Direct and indirect energy-related emissions (covered under VSME B3)
- VOC: Volatile Organic Compound (relevant for printing or production, not office work)