Can I Use Industry Averages for CSRD Reporting?
Introduction
It’s a common challenge: your company needs to report energy use, emissions, or waste data under the Corporate Sustainability Reporting Directive (CSRD) — but you don’t have all the numbers. Can you use industry averages instead?
Yes, you can — provided you do so transparently and proportionately. Both the CSRD Directive (EU 2022/2464) and VSME Standard (EFRAG 2024) recognise that smaller businesses may not have complete data in their early reporting years. Using reliable benchmarks is acceptable when actual data is unavailable or costly to collect, as long as your sources and assumptions are clearly documented.
This guide explains when averages are appropriate, how to find credible sources, and what to include in your disclosures.
For help with broader data estimation techniques, see our article on how to estimate missing data for CSRD reporting.
1. When Using Industry Averages Is Appropriate
Under CSRD and VSME guidance, you can use industry averages when:
- You lack direct measurement data (e.g. missing invoices, no energy meters).
- Supplier data is unavailable, especially for Scope 3 emissions.
- Data collection costs would be disproportionate to your company’s size or impact.
This approach is particularly relevant for SMEs in supply chains who need to provide sustainability data to larger CSRD-reporting clients but may not have full environmental tracking systems in place.
However, averages should never replace real data if it’s reasonably available. They’re a bridge, not a permanent substitute.
2. How to Choose Reliable Averages
When selecting an industry benchmark or average, use public, verifiable, and regionally relevant sources. Examples include:
- Eurostat or European Environment Agency (EEA) data
- National energy agencies (e.g. ADEME in France, Umweltbundesamt in Germany)
- Sectoral sustainability reports or trade associations
- Academic or government studies that publish emissions intensity data
For instance, if you run a logistics SME and lack precise fuel data, you might use:
“Average diesel emissions intensity for light commercial vehicles: 2.68 kg CO₂e/litre (EEA 2023).”
Always cite the year, source, and regional scope of the dataset.
3. Applying Averages to Your Data
Here’s how to use averages effectively and transparently:
| Data Type | Example of Using Industry Average | Disclosure Example |
|---|---|---|
| Energy use | Use kWh per m² for similar facilities in your sector | “Office energy use estimated using 130 kWh/m²/year (EU office benchmark).” |
| Scope 3 emissions | Use spend-based emissions factors by sector | “Purchased goods emissions estimated using €0.45 CO₂e per €1 spend (EEA factor).” |
| Water consumption | Apply per-employee averages | “Estimated at 12 m³/employee/year based on EU industry data.” |
| Waste generation | Use kg waste per employee or unit produced | “Estimated 150 kg/employee/year (manufacturing sector average).” |
For financial alignment, ensure your averages use the same reporting year and functional unit (e.g. per m², per employee, per € of turnover).
4. How to Disclose the Use of Averages
Transparency is critical. Clearly state:
- Which data points were estimated using averages.
- The source of the benchmark.
- Why the method was used (e.g. lack of data, supplier non-response).
- Plans to collect direct data in the future.
Example disclosure note:
“Scope 3 emissions were estimated using average EU emission factors for service industries (EEA, 2023), as supplier-specific data was unavailable. Direct data collection is planned from FY2026.”
This meets the CSRD’s expectation of traceability and aligns with the VSME principle of proportionality.
5. How to Transition from Averages to Real Data
Over time, replace estimated data with company-specific measurements. Here’s how:
- Set up automatic data feeds for energy and fuel invoices.
- Request ESG data from key suppliers annually.
- Keep a record of which data points remain estimated.
- Review your estimation sources each year for updates.
Most SMEs move from 50% estimated data in their first report to 80–90% actual data by their third reporting cycle.
Frequently Asked Questions
Can I use global data if EU data isn’t available?
Yes, but prioritise European sources where possible. If using global data, note its geographic scope clearly. For example:
“Emission factors derived from global averages (IEA 2022) — regional adjustment pending.”
Do auditors accept the use of averages?
Yes, if your approach is logical and documented. Auditors look for consistency, traceability, and disclosure, not perfection.
How often should I update my averages?
At least every two years, or sooner if new EU or national benchmarks are released. Outdated factors can misrepresent your performance trends.
Can I use the same average across multiple years?
You can, but include a note that the value remains unchanged and review its relevance annually. Consistency is good — but accuracy improves credibility.
Key Terms
- Industry average – Typical or benchmark performance values for a sector, used to estimate missing data.
- Estimation – Calculated data based on assumptions or proxies rather than direct measurements.
- Scope 3 emissions – Indirect GHG emissions from suppliers, products, or services.
- VSME Standard – EFRAG’s voluntary sustainability reporting framework for SMEs.
- Proportionality – Principle allowing smaller companies to report scaled-down data appropriate to their size and resources.
Conclusion
Using industry averages is a legitimate and practical approach for SMEs starting their CSRD or VSME reporting journey. As long as the source is credible and the methodology transparent, averages can fill short-term data gaps while your systems mature.
Over time, replace proxies with actual data to enhance accuracy and demonstrate continuous improvement — a key CSRD principle.
For next steps, explore our detailed guide on how to estimate missing data for CSRD reporting.