CSRD Reporting for Retail: Energy Use in Shops and Warehouses

Retailers and wholesalers operate in energy-intensive environments — from lighting, heating, and refrigeration in shops to logistics and storage in warehouses. Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), understanding and reporting your energy use is a core environmental requirement.

This guide explains how retail and wholesale businesses can measure, manage and report energy consumption clearly and confidently.

1. Why Energy Reporting Matters for Retail and Wholesale

Energy is often one of the largest operating costs in retail and wholesale. Reporting energy use helps your business to:

• Comply with CSRD (if within scope) or prepare voluntarily using the VSME Standard.
• Identify inefficiencies — such as poorly insulated warehouses or outdated lighting.
• Cut costs through targeted energy improvements. Learn more about how to report electricity use from utility bills.
• Meet supply chain expectations, as larger companies will request sustainability data from their retail and logistics partners.

Under Article 19a of the CSRD, all large undertakings and listed SMEs (except micro-entities) must disclose environmental information, including energy consumption and greenhouse gas (GHG) emissions.

Unlisted small businesses can use the VSME Basic Module (B3 – Energy and GHG emissions) to report proportionately.

2. Who Must Report?

a. Mandatory Reporting under CSRD

You are within CSRD scope if your company exceeds two of the following three thresholds:

• 250 employees
• €40 million turnover
• €20 million total assets

These thresholds apply to retail groups, including parent companies with consolidated operations (e.g., national chains operating multiple stores).

b. Voluntary Reporting under VSME

Unlisted micro, small and medium-sized retailers and wholesalers can adopt the VSME Standard:

VSME reporting helps these businesses respond to requests from larger clients or banks while improving internal energy management.

3. What to Report: Energy and GHG Disclosures

The VSME Basic Module (B3) sets clear energy and emissions metrics suitable for shops, warehouses, and offices.

a. Total Energy Consumption

Report total annual energy use in megawatt hours (MWh), broken down by source:

You can obtain this data from utility invoices, fuel receipts, or smart meter readings.

b. Greenhouse Gas (GHG) Emissions

Disclose emissions using the GHG Protocol Corporate Standard (2004):

• Scope 1: Direct emissions from owned sources (e.g. gas heating, company vehicles)
• Scope 2: Indirect emissions from purchased electricity or heat See our step-by-step guide to reporting Scope 1 and 2 emissions for more details.

Example:

“Total Scope 1 emissions: 50 tCO₂e; Scope 2 emissions: 70 tCO₂e (location-based).”

Optional: include Scope 3 (e.g. third-party logistics or product transport) if material to your operations.

c. Energy Intensity

Calculate:

Energy Intensity = Total Energy Use / Turnover (€)

and/or

GHG Intensity = Total Emissions / Turnover (€)

This helps track efficiency over time — useful for both CSRD and VSME reports.

4. Practical Steps for Retailers and Wholesalers

Step 1. Gather Data

Start with your most accessible information:

• Electricity and gas bills from stores and warehouses.
• Fuel consumption from delivery or company vehicles.
• Data from building management systems or sub-meters.

If you rent your premises, request energy data from your landlord.

Step 2. Convert Units

Convert kWh, litres, or cubic metres into MWh and CO₂e using emission factors from your national authority or the European Environment Agency.

Step 3. Separate Energy Types

Distinguish renewable from non-renewable energy. Many suppliers show renewable percentages on invoices.

Step 4. Record Improvements

Note efficiency actions such as:

• Installing LED lighting.
• Replacing refrigeration units with energy-labelled models.
• Adding motion sensors or solar panels.

You can describe these initiatives under VSME Disclosure B2 (“Practices, policies and future initiatives”).

Step 5. Set Reduction Targets

Under the Comprehensive Module (C3), you can set measurable goals, e.g.:

“Reduce electricity consumption by 15% per square metre of retail space by 2027.”

Include your base year, target year, and planned actions.

5. Example: Reporting for a Medium-Sized Retail Chain

Company: GreenGrocer Ltd Operations: 20 food shops + 2 warehouses (Belgium) Annual turnover: €25 million Employees: 180

Improvement actions:

• Switched to renewable electricity contract.
• Installed LED lighting across all shops.
• Introduced automatic door closers to reduce heat loss.

6. Linking CSRD and VSME Reporting

Retailers supplying large chains or listed groups benefit from aligning with VSME — it mirrors ESRS but at a manageable level.

7. Common Challenges and Solutions

8. How to Present Energy Information

In your sustainability or management report:

Example wording:

“In 2025, ShopSmart Ltd consumed 2,800 MWh of energy (35% renewable). Scope 1 emissions were 210 tCO₂e and Scope 2 were 180 tCO₂e. We aim to reduce total electricity use by 10% by 2026 through smart lighting and upgraded warehouse insulation.”

Attach tables and graphs where helpful, and note if figures are estimated or based on bills.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464) requiring large and listed companies to disclose sustainability data.
• VSME – Voluntary Sustainability Reporting Standard for SMEs by EFRAG (2024).
• Basic Module – Core disclosures (B1–B11) suitable for micro and small firms.
• Comprehensive Module – Extended disclosures (C1–C9) for advanced reporting.
• ESRS – European Sustainability Reporting Standards for CSRD.
• SME – Small and Medium-Sized Enterprise.
• Scope 1 and 2 emissions – Direct and indirect GHG emissions from owned and purchased energy.
• Turnover – Annual revenue from goods or services.

Before you start reporting energy use, check whether CSRD applies to your business and what you need to prepare:

This tool will help you understand your reporting obligations and prepare for energy data collection.