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What Happens If My CSRD Data Is Wrong?

Introduction

It is a common worry for a small business handed its first ESG questionnaire: what if some of the data turns out to be wrong?

Start with what does not happen. Since the Omnibus I directive (in force 18 March 2026), no small or medium-sized business (SME) reports under the Corporate Sustainability Reporting Directive (CSRD). Only companies with more than 1,000 employees and over €450 million turnover file, so there is no auditor waiting to fail your figures. See what the Omnibus changed for the detail.

The real risk sits somewhere else. The data you worry about is usually data you have already sent to a customer or a bank, in a VSME report or a supplier questionnaire. If it is wrong, the consequences are about trust, contracts, and correcting the record, not about a regulator.

This article explains where your data goes after you send it, what happens when an error surfaces, and how to correct it without damaging the relationship. For how precise the numbers need to be in the first place, see How Accurate Does CSRD Data Need to Be?.


1. Where Your Data Goes After You Send It

When a large customer or bank asks you for ESG data, your figures rarely stay in an inbox. They typically feed into:

  • The customer’s own CSRD report, where your energy or emissions data becomes part of their value-chain (Scope 3) disclosures.
  • The customer’s assurance process. CSRD reports carry limited assurance, meaning an auditor checks that the data behind them is plausible and traceable, including supplier inputs.
  • A bank’s credit or risk assessment, where ESG figures can influence how your business is evaluated.

That is why a wrong figure matters even without an audit of your own: someone else is building on it, and their auditor may trace a query back to you.


2. Honest Errors Are Expected, Misleading Figures Are Not

The reporting frameworks themselves assume imperfection. Estimates are acceptable, for suppliers as much as for reporters, provided:

  • The method is sound,
  • The assumptions are stated, and
  • The margin of error does not change the conclusion the reader draws.

Under the voluntary VSME standard, the format most SMEs use to answer requests, proportionality applies. A small data error handled openly is routine. A figure that paints a false picture, such as claiming fully renewable electricity without evidence, is the real problem, because your customer may repeat that claim in an assured public report.


3. What Happens When an Error Surfaces

In practice the sequence usually looks like this:

  1. A query arrives. The customer’s sustainability team, or their auditor, spots an inconsistency and asks for backup documentation.
  2. You clarify or correct. If the figure was wrong, you send a corrected version and briefly explain what changed.
  3. The customer updates their records. If their report has already been published, they handle any restatement on their side.

Handled promptly, this usually ends the matter. The risks grow when errors are ignored or repeated:

  • Trust: a supplier whose numbers keep failing plausibility checks creates work and doubt for the buyer.
  • Contracts: supplier agreements and codes of conduct increasingly require accurate ESG information, so persistent bad data can become a contractual issue and count against you at renewal or in tenders.
  • Deliberate misstatement: knowingly false claims to a customer or bank are a different category altogether, with commercial and legal consequences well beyond ESG.

4. How to Correct Data You Have Already Sent

If you find an error before sending, fix it and keep a note of the correction. If you find it after sending:

  1. Tell the recipient, without waiting to be asked. A short message with the corrected figure and the reason is enough.
  2. Document what changed and why (for example, “updated the electricity emission factor from the 2024 to the 2025 version”).
  3. Restate the figure in your next report, with a brief note, mirroring financial reporting practice.

Example wording:

“Scope 2 electricity emissions for 2025 were revised from 220 tCO₂e to 190 tCO₂e following updated utility data.”

Volunteering a correction reads as competence, not failure. Buyers deal with far worse than an honest restatement.


5. Common Causes of Incorrect Data (and How to Avoid Them)

Common IssueExampleHow to Avoid It
Inconsistent data sourcesDifferent sites using different energy unitsUse a central data template
Outdated emission factorsUsing 2023 factors for 2026 dataReview annually
Double countingReporting the same emissions twice across scopesReconcile energy, fuel, and spend totals
Estimation without documentationCalculated waste figures with no record of methodKeep assumptions in your files
Human errorTypo in a spreadsheet or a unit mix-upApply peer checks or software validation
Retyping between questionnairesA figure copied differently into two requestsAnswer from one master dataset

The last row is specific to businesses answering multiple requests: every questionnaire retyped by hand is another chance to create a discrepancy between what two customers hold about you.


6. Why Consistency Across Requests Matters

If three customers ask similar questions and receive three slightly different answers, none of the figures is necessarily wrong, but the inconsistency itself invites queries. Under the value-chain cap, what CSRD reporters may request from smaller suppliers is capped at the VSME standard, so one VSME report can answer nearly every request.

Keeping a single source of truth, one dataset that every answer draws from, prevents most self-inflicted errors and makes any correction a single update rather than a hunt through old emails.


Frequently Asked Questions

What if I cannot get full data for some figures?

You can use estimates or industry averages, as long as the approach is stated. See How to Estimate Missing Data for CSRD Reporting.

Can I correct data after I have sent it to a customer?

Yes. Send the corrected figure with a short explanation, and restate it in your next report or questionnaire response. Recipients expect iterative improvement, especially in early reporting years.

Could my error affect my customer’s audit?

Possibly. Supplier data feeds their value-chain disclosures, and their limited assurance checks that the data is plausible and traceable. A material error might trigger a query back to you, which is exactly why a prompt, documented correction is the right move.

What is the best defence against wrong data?

Documentation and a single dataset. Keep a clear trail of how each figure was calculated, including sources and emission factors, and answer every request from the same master data rather than retyping.


Key Terms

  • Limited assurance – The moderate-level audit applied to CSRD reports (your customer’s, not yours), confirming data is plausible and traceable.
  • Restatement – Correcting a previously shared figure in a later report, with a brief note.
  • Emission factor – Conversion rate between activity data and emissions.
  • VSME Standard – The voluntary EFRAG reporting standard SMEs use to answer ESG requests.
  • Value-chain cap – The post-Omnibus rule capping what CSRD reporters may request from smaller suppliers at the VSME standard.

Conclusion

If data you sent to a customer or bank turns out to be wrong, do not panic. There is no CSRD audit waiting for your business; what is at stake is the relationship, and relationships survive honest, prompt corrections far better than silence.

Correct openly, document your methods, and keep one master dataset so every request gets the same answer. Free VSME report tools with built-in validation checks can catch unit errors and gaps before a figure ever leaves your business.


To help ensure your data is accurate from the start, use the checklist generator to create a data collection checklist:

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