Who Should Own CSRD Reporting in Your SME?

Introduction

One of the first questions small and growing businesses (SMEs) face when preparing for the Corporate Sustainability Reporting Directive (CSRD) is: who should actually take ownership of it? Unlike financial reporting, sustainability data cuts across every department — energy use, HR policies, supplier practices, and more. That makes CSRD governance a shared responsibility, but clear ownership is essential for accuracy, efficiency, and compliance.

This article helps you decide which role or team should lead CSRD reporting in your SME, how to structure collaboration, and how to make ownership sustainable over time.

Why Ownership Matters

Under the CSRD, sustainability data must be reliable, consistent, and auditable — the same standard applied to financial data. Without clear accountability, sustainability reports can become disorganised collections of spreadsheets and assumptions.

Strong ownership ensures:

• Regular data updates and internal controls.
• Consistent communication with external auditors and stakeholders.
• A single source of truth for sustainability metrics.

Step 1: Choose a Lead Function

For most small and growing businesses, the CSRD reporting lead will come from one of three functions:

1. Finance

The finance department is already used to deadlines, audits, and structured reporting. Finance-led CSRD ownership works best when the company wants to integrate sustainability metrics into management reporting and budgeting.

Pros: Strong data discipline, familiarity with audit processes. Cons: May lack environmental or social expertise.

2. HR or Operations

If your biggest reporting topics are social (e.g. workforce, training, diversity), the HR or operations function may be a natural lead. This is especially true in service industries or people-driven businesses.

Pros: Direct access to social and workforce data. Cons: Limited exposure to environmental reporting requirements.

3. Sustainability or ESG Coordinator

Larger small and growing businesses may already have someone managing sustainability or certifications (e.g. ISO 14001). This person can serve as the reporting coordinator, working cross-functionally to collect data and draft disclosures.

Pros: Holistic understanding of sustainability. Cons: May lack authority to gather data from other teams without executive backing.

Learn how to build your CSRD reporting system →

Step 2: Appoint an Internal “CSRD Champion”

Even small teams benefit from having a CSRD Champion — a named person who drives the process and ensures all departments stay aligned. This doesn’t have to be a full-time role; 4–6 hours per month is often enough once systems are in place.

The champion’s key tasks include:

• Coordinating data collection and updates.
• Keeping templates and documentation consistent.
• Liaising with management and external partners.

A simple internal mandate — endorsed by leadership — can clarify their authority and ensure timely cooperation.

Step 3: Create a Cross-Functional Team

CSRD reporting depends on multiple data owners:

• Facilities or operations: Energy, waste, and water data.
• HR: Workforce metrics and diversity.
• Finance: Financial KPIs and links to annual reports.
• Management: Approval and strategic direction.

Assign each owner specific metrics, aligned with the VSME Basic Module structure. Meet quarterly to review updates and prepare for the reporting deadline.

Discover how small and growing businesses (SMEs) collect sustainability data efficiently →

Step 4: Link Ownership to Business Goals

To make CSRD ownership meaningful, link sustainability KPIs to existing business goals — for example:

• Reducing energy use by 10% per year.
• Increasing staff training hours.
• Improving supplier sustainability screening.

This turns CSRD reporting from a compliance burden into a management tool that supports performance and growth.

Step 5: Formalise the Process

Document who owns what. A basic “Responsibility Matrix” can go a long way:

Storing this matrix alongside your sustainability data makes the process clear and auditable.

Learn about cost-effective reporting structures →

Frequently Asked Questions

Who should lead CSRD reporting in a small company?

In small businesses, CSRD reporting is usually best managed by the finance director or operations manager, supported by HR and management. The key is having someone organised who can coordinate across teams, even if sustainability isn’t their primary role.

Can CSRD reporting be outsourced?

Yes, but outsourcing should complement, not replace, internal ownership. Consultants or tools can help with data structure and assurance, but your team must still provide accurate source data and sign-off on disclosures.

Compare manual vs software CSRD reporting →

What if no one in my SME has sustainability experience?

That’s common. Start by assigning a motivated team member and giving them access to resources like the VSME Standard or free training guides. Over time, they’ll develop the internal know-how to manage reporting without consultants.

See how small and growing businesses (SMEs) start with VSME reporting →

Key Terms

• CSRD: Corporate Sustainability Reporting Directive — EU law standardising sustainability disclosures.
• VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024).
• ESRS: European Sustainability Reporting Standards — defines what and how to report.
• CSRD Champion: An internal coordinator who manages sustainability data and timelines.
• Governance: The internal structure defining accountability, decision-making, and control.

Conclusion

Every small and growing business (SME) needs a clear owner for CSRD reporting — but it doesn’t require a new department or a full-time role. Start with one accountable person, supported by a cross-functional team and simple documentation. With clear governance and structure, you’ll build both compliance confidence and long-term sustainability value.

Get started with CSRD compliance essentials →