How can the company adjust the applicability of its indicator in the Data Collection module?
How can the company adjust the applicability of its indicator in the Data Collection module?
In the Data Collection module, Greenly offers a "Materiality" property for each questionnaire and question, which the company can adjust as needed. This "Materiality" property is set at the start of the data collection process, after the double materiality results are finalized (triggering an update to the materiality of the data points based on the mapping of sub-topics to data points). If the company chooses to change the materiality of a form or question, it can provide a justification in the dedicated comment box.
What should the company do if it is unable to respond to an applicable indicator in the Data Collection module?
What should the company do if it is unable to respond to an applicable indicator in the Data Collection module?
There are two possible scenarios:
1. If the question is not relevant to the company (for example, if it's sector-specific), the company should select the "I can't answer the question" option below the question. They should then choose "Not applicable to my company" and provide a justification in the Explanation Field. In this case, the question and any related data points will be excluded from the reporting perimeter.
2. If the question is applicable but the company does not yet have the data, it should select the "I can't answer the question" option and choose "Not available." A justification should be provided in the Explanation Field. In this scenario, the question and related data points will remain within the reporting perimeter, and the Gap Analysis system will take the lack of data into account.
Does the software provide guidance to users on selecting appropriate data sources for each indicator?
Does the software provide guidance to users on selecting appropriate data sources for each indicator?
Greenly’s documentation suggests resources to help identify relevant sources within the company for addressing the various ESG requirements.
Can the software track when data is marked as "Not Applicable" or "Not Available," and does it offer explanations for these statuses?
Can the software track when data is marked as "Not Applicable" or "Not Available," and does it offer explanations for these statuses?
Yes, the system distinguishes between these two scenarios using the "I can't answer the question" option at the question level. When selected, the user must choose a specific reason (e.g., not applicable, not available). The system then provides a comment box, where the company is encouraged to provide more details about why this choice was made, though completing this field is not required.
Can the software log changes made to data entries in the data collection module, including audit trails for traceability?
Can the software log changes made to data entries in the data collection module, including audit trails for traceability?
A new version of the Greenly data collection system will offer indeed audit logs and trails. The user will be able to trace back any action and status change for any indicator, and have the possibility to reverse some change to get back to an older version of the content.
To be released by Q3 2025.
Is the software updated regularly to reflect changes in disclosure requirements made by ESG institutions and regulators?
Is the software updated regularly to reflect changes in disclosure requirements made by ESG institutions and regulators?
Yes, our R&D team continuously monitors the market to ensure our methodology stays current. Here are some of the sources we track: GRI, ISSB, EFRAG, H2A, AMF, ANC, Ministère de la Transition Écologique, Ministère de la Justice (Audit)...
Are users required to document the assumptions, exclusions, estimates, and methodologies used during data collection?
Are users required to document the assumptions, exclusions, estimates, and methodologies used during data collection?
Yes, several cases address this requirement:
- Some frameworks specifically ask for the methodology used to determine the information.
- For all datapoints, the Greenly system provides a comment section (within each form) where the user—whether the data owner or validator—can add details about context, assumptions, decisions, etc. While this feature is optional, it is up to the user to decide whether to use it.
Is the company allowed to use proxy for quantitative datapoints (metrics, financial amounts)?
Is the company allowed to use proxy for quantitative datapoints (metrics, financial amounts)?
It is authorized, as explicitely described in CSRD Delegated Act, ESRS 1, paragraphs 68, 69, 72, 87, 88, 89. ("7.2 Sources of estimation and outcome uncertainty" section).
Paragraph 89: "The use of reasonable assumptions and estimates, including scenario or sensitivity analysis, is an essential part of preparing sustainability-related information and does not undermine the usefulness of that information, provided that the assumptions and estimates are accurately described and explained. Even a high level of measurement uncertainty would not necessarily prevent such an assumption or estimate from providing useful information or meeting the qualitative characteristics of information."
Are there automated mechanisms for detecting errors, inconsistencies, or gaps in the data inputs?
Are there automated mechanisms for detecting errors, inconsistencies, or gaps in the data inputs?
Currently, data quality assurance is not automated within the platform. It is carried out manually through collaboration between the reporting company, its validator user and Greenly's CSRD expert team.
Once CSRD benchmarks and sector standards are fully integrated into Greenly's platform, the software will be able to automatically perform quality checks, ensuring data accuracy while reducing the need for manual involvement.
How do I determine if a required KPI is either not applicable or not available for my company ?
How do I determine if a required KPI is either not applicable or not available for my company ?
Non-applicability refers to a situation where a specific data point does not apply to your company’s sector or operations at all. The company is not required to disclose this information because it is irrelevant to its business model, industry, or operational scope
Non-availability occurs when the company currently lacks the data or systems to report on a particular data point. However, this gap can be filled in the future by deploying additional resources, processes, or technologies. In this case, the data could eventually become available with the right investments or actions.
1. To indicate that a data point is not available, click on it and then click "I can't answer this question". You can then choose the reason "The data is not available" or "The data is not measured". You can then justify your answer.
2. To indicate that a data point is not applicable, click on it and then click "Ignore Question". You can then choose the reason "Not material" or "Not applicable"
What should be done in case of data unavailability ?
What should be done in case of data unavailability ?
Case 1: The Datapoint is a Metric
Metrics are quantitative data points, such as greenhouse gas (GHG) emissions, employee information, or salary data.
How to Isolate Metric Datapoints in Greenly Platform?
Use the specific column in the database to filter for metric datapoints (value = “”).
What Alternatives Do I Have in Case of Data Unavailability for a Metric?
Unfortunately, there are no alternatives. You must report something, even if based on a simple assumption or theoretical calculation. If no actual data is available, select the "answer is a proxy" option to flag this datapoint properly. This is crucial for gap analysis and future audits.
Common Metrics to Report:
GHG Assessment
Employee General Information
Salaries
Case 2: The Datapoint is NOT a Metric
These include policies, actions, targets, financial effects, processes, materiality metrics, transition plans, reporting, report preparation, and business models.
What Alternatives Do I Have in Case of Data Unavailability for Non-Metric Datapoints?
Check the “I don’t have the information” option in the datapoint form and confirm its completeness. For now, no further action is required, but you will need to plan for future data provision.
Steps to Follow:
Identify Solutions and Initiatives: During the “ESG Roadmap” stage, outline what solutions and initiatives you will implement in the near and mid-term to obtain the missing information.
Set Timelines: Determine when you will be able to provide the necessary data for CSRD reporting.
What material datapoints are applicable to my company ?
What material datapoints are applicable to my company ?
Assign first all material forms to the relevant stakeholders (Owners, Validators)
You must decide if you cover only mandatory forms, or also optional ones
Make people check the applicability of the required data (depending on its sector, on knowledge about required material to produce it, etc)
Make sure that people don’t confuse non-applicability with non-availability of the data (read and share this article that explains the topic in more details)Have the identified questions as non-applicable reviewed by the ESG Reporting Project Manager
If the project manager agrees about the non applicability of the identified question, then for each identified question:
Choose the “Not Applicable” option
If possible, provide a justification of it using the “Explanation field”
What is the scope for reporting sustainability information ?
What is the scope for reporting sustainability information ?
Value Chain Analysis: Sustainability issues are analyzed across the entire value chain, similar to how we identify the company's risk factors.
Policies, Actions, and Targets: These have a defined scope set by the company, meaning their implementation scope is under the company's control. For example, human rights policies often cover a broader scope than the financial scope, especially in the context of French duty of vigilance.
Sector-Wide Indicators: These should generally be reported for the company's own operations. However, for some indicators, a broader scope may be considered (see the box below for details).
Regarding indicator information, the general principle is to establish symmetry between the consolidation scope of financial information and that of sustainability information. Entities included in the scope for calculating indicators are those consolidated at 100% in the financial statements. This also includes, where applicable, subsidiaries under exclusive control that are not consolidated due to financial materiality but may be considered under impact materiality.
An indicator considered material at the group level should include all entities (parent companies and controlled subsidiaries) that constitute the company's own operations and be reported on this scope. However, if an entity's contribution is insignificant, it may be omitted from the indicator calculation, provided the insignificance is justified and methodological consistency is maintained over time (e.g., the environmental impacts of small tertiary establishments in industrial companies with significant environmental impacts).
For a subsidiary under the scope of the CSRD to benefit from an exemption from publishing sustainability statements, a consolidated sustainability statement must be published at the parent level, including this subsidiary. This exemption does not apply to subsidiaries that are large listed companies (debt or equity securities) on a regulated market in the European Union (EU).