Connecting soil information and your sustainability reporting obligations under the CSRD

27 September 2023, Michael Dumas

Throughout the lifecycle of your industrial site, proper soil management is a recurring concern. Whether implementing preventive measures through Best Available Techniques, investigating soil in line with Industrial Emission Directive (IED) obligations, or addressing product leakages and subsequent remediation, land stewardship holds a pivotal place in the (re)development of your sites. 

As the implementation of the Corporate Sustainability Reporting Directive (CSRD) approaches, you may be wondering how soil questions tie into the CSRD, if reporting is required, and how to prepare.

The CSRD is a new European directive that will require large companies operating in the EU, including many of our industrial, real estate, and contractor clients, to become more transparent on the topic of impacted soils in the coming years. This directive aims to promote transparency, standardization, and comparability and increased quality of environmental, social, and governance (ESG) information for external stakeholders (investors, consumers, policy makers, NGOs, etc.). In short, it brings sustainability reporting to the same level as financial reporting.

CSRD blog series: With the implementation of the CSRD fast approaching, TAUW takes you through the ins and outs of this directive and takes a deeper dive into different environmental topics and how they link to the CSRD. 

Recently the EU commission has approved a delegated act that sets out how companies will have to do this reporting in practice. This includes the approval of the European Sustainability Reporting Standards (ESRS). There are two cross-cutting standards and ten topical standards (covering 10 different ESG topics). Sector-specific standards will be published in the years to come. Each ESRS document defines a series of disclosure requirements, which are the qualitative and quantitative information that will have to be reported.


Double materiality assessment as a starting point

If you are subject to the CSRD, complying with this directive will begin with a double materiality assessment, which involves determining if a specific ESG topic is relevant in terms of its implications for the company's financial value and/or impact on the world at large. For soil and groundwater, this assessment will involve analyzing the impact of the company's activities on these important natural resources. Most elements linked to soil and groundwater contamination and remediation are covered by the ESRS E2 on pollution. When looking to the broader ecosystem services of soil, there are strong links as well to the ESRS's relative to climate change, biodiversity as well as circular economy. 


Links between impacted soil stewardship and the CSRD

Five key takeaways regarding information to be disclosed on soils in the CSRD when it is considered relevant for your company are the following:

  1. Policies and Targets: companies will have to disclose their policies addressing prevention of contamination of soils, assessing potential impacts and managing, or remediating contaminated as well as specific targets the company sets on this topic. An example of a prevention target could be reducing the use of substances of concern by 10% over 3 years.
  2. Actions undertaken or planned: Companies will have to report actions undertaken or planned to avert incidents that can impact soils, such as secondary containment installations, as well as allocated resources.
  3. Incidents impacting soil: When addressing product spills to soil, companies must divulge spill incidents, including only sites where spills surpass yearly thresholds as defined in the European Pollutant Release and Transfer Register (E-PRTR). For example, any spill of Naphthalene to land exceeding the threshold of 10 kg for that year on a site must be reported.
  4. Contaminated soil and landfills: Companies must disclose the capital and operational costs related to soil remediation and site or landfill rehabilitation in the ongoing year as well as expected financial impacts regarding risks but also opportunities.* This information will have to include a comprehensive contextual overview.
  5. Phased Approach: The Commission has set out a phased approach for the previous point (concerning financial effect of pollution on the company). For the first year of reporting, the company does not have to report on this. For the initial three years of reporting, qualitative disclosures are acceptable, except for capital and operational cost reporting.

As an environmental consultant covering matters such as soil management, TAUW is well-positioned to help you identify the relevant, valuable, and necessary information for reporting, drawing upon our deep understanding of your activities, sites, and specific soil contamination scenarios.

*Sustainable soil management including decontamination of soils can, in certain cases, be considered an EU taxonomy aligned activity - more on this in a later article.

Navigating the new CSRD reporting requirements with ease

At TAUW, we support our clients on the following aspects on their road to CSRD compliance:

  • Guidance: We inform clients about CSRD requirements and help them understand the implications for their existing business and strategies.
  • Developing a strategy and target setting: We help clients develop a strategy and target setting for a specific environmental topic, such as biodiversity, pollution, circular economy, and more.
  • Compliance & reporting support: We ensure clients meet EU CSRD and ESRS requirements with minimal risk, high efficiency, and maximum strategic or commercial value (includes data collection).

As a business, if you identify soil impacts as a material topic, understanding the connections between the topic and upcoming CSRD reporting obligations is crucial. This understanding will help your organization to collect the necessary information and ensure it aligns coherently with CSRD requirements. The deadline for compliance with the CSRD is approaching. It is therefore paramount to be well-informed about the link between material environmental topics and reporting obligations. At TAUW, we are committed to helping you navigate this complex process and ensure that your organization is compliant with the upcoming CSRD reporting requirements.

Do you have any questions about this topic?

Contact us today to engage further on this topic and streamline the process.