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What Disclaimers you must include in your CSRD report.

When preparing a Corporate Sustainability Reporting Directive (CSRD) report, it’s essential to include disclaimers to manage legal risks and clarify the limitations of the information provided. CSRD reports contain sensitive data and forward-looking statements that may be subject to external variables and uncertainties. Here’s a guide to the types of disclaimers every CSRD report should consider.

1. Forward-Looking Statements Disclaimer

Many CSRD reports include projections on future sustainability goals, such as emissions reductions or resource usage. These statements involve uncertainties beyond a company’s control, including regulatory changes, market conditions, and technological advancements. To manage expectations, include a disclaimer highlighting that these statements are based on current assumptions and may not reflect actual future outcomes. For more on forward-looking statements, visit the European Securities and Markets Authority (ESMA).

Example:
“This report contains forward-looking statements reflecting our current expectations. These statements are based on assumptions and involve risks beyond our control. Actual results may differ, and we disclaim any obligation to update these forward-looking statements.”

2. Data Limitations and Accuracy Disclaimer

Accurate sustainability data can be challenging to gather, especially in complex areas like Scope 3 emissions, energy usage, and resource consumption. Variations may occur due to estimation methods, data collection techniques, or the use of third-party sources. By including a data limitations disclaimer, companies can manage stakeholders’ expectations about data precision. Find guidance on sustainability data accuracy from the Global Reporting Initiative (GRI).

Example:
“While every effort has been made to ensure data accuracy, certain figures are based on estimates or third-party sources. Data limitations may affect the precision of some information disclosed herein.”

3. Assumptions Disclaimer

Many figures in a CSRD report rely on assumptions – for instance, projected renewable energy adoption rates or anticipated carbon offsets. Including a clear disclaimer about assumptions can prevent stakeholders from misinterpreting projections. This provides context for readers on the foundational elements of your estimates. For more information on emissions assumptions, visit the Greenhouse Gas Protocol.

Example:
“All data and projections provided in this report are based on specific assumptions about external factors, such as market trends and regulatory changes. These assumptions are subject to change, potentially impacting projections.”

4. Materiality Disclaimer

The CSRD requires companies to focus on material sustainability issues relevant to stakeholders, operations, and compliance requirements. However, not all environmental, social, or governance (ESG) issues may be considered material. A disclaimer explaining how materiality was determined can help clarify why certain areas were prioritised over others. For more on materiality, explore the Sustainability Accounting Standards Board (SASB).

Example:
“This report addresses sustainability issues deemed material to our operations and stakeholders. We acknowledge that other issues may be relevant but are not included here due to their lower materiality or data availability constraints.”

5. Third-Party Data Disclaimer

CSRD reports frequently rely on external data sources, such as industry benchmarks or emissions factors. To be transparent, a third-party data disclaimer acknowledges the limitations and potential discrepancies in this information. Visit the International Organization for Standardization (ISO) for more information on sustainability standards and third-party data.

Example:
“Some data in this report is provided by third parties. While we believe these sources are reliable, we cannot guarantee the accuracy of third-party data and disclaim responsibility for any discrepancies.”

6. Non-Financial Nature Disclaimer

Since CSRD reports contain predominantly non-financial information, they may not meet the same standards as audited financial statements. A non-financial disclaimer clarifies this distinction for stakeholders, helping avoid misinterpretation. To understand more about non-financial disclosures, check the European Commission’s guidelines.

Example:
“This report is primarily non-financial in nature and has not been audited under financial reporting standards. Non-financial data herein is subject to different verification and reporting guidelines.”

7. Regulatory Compliance Disclaimer

With CSRD standards continually evolving, it’s important to state that the report aligns with existing CSRD requirements as of its publication date. This helps companies manage their compliance obligations as regulations shift. For up-to-date information on CSRD regulations, visit the European Parliament.

Example:
“This report aims to fulfil the Corporate Sustainability Reporting Directive (CSRD) requirements as of the publication date. Future regulatory changes may necessitate updates to our reporting practices.”

Conclusion

Incorporating these disclaimers into a CSRD report fosters transparency and protects against potential legal and interpretive risks. By clarifying data accuracy, assumptions, materiality, and limitations, companies can responsibly manage expectations and support regulatory compliance as they pursue their sustainability commitments.