CSRD/ESG reporting in SAC: structuring Scopes 1, 2 and 3

CSRD is the EU directive that decides who must publish sustainability information; the ESRS are the standards that decide what they disclose. At the centre of both sits the carbon footprint — greenhouse-gas emissions across Scopes 1, 2 and 3. In a SAP Analytics Cloud model those emissions are the spine: structure them correctly, with the right scopes, factors and intensity ratios, and the disclosures and reduction targets fall out. This guide explains what CSRD and the ESRS require in 2026 — after the Omnibus reform — and how to build the emissions model in SAC.

CSRD and ESRS: two different things

The Corporate Sustainability Reporting Directive (CSRD) is the legal framework — it sets which companies report and when. The European Sustainability Reporting Standards (ESRS), developed by EFRAG and adopted by the European Commission, are what teams work with day to day: the disclosure structure, the datapoints and the evidence expected. CSRD decides scope; ESRS decides content. A SAC model lives almost entirely in the ESRS world — it produces the quantified disclosures the standards demand.

Double materiality — the methodological core

The defining principle of CSRD is double materiality, and the Omnibus reform left it untouched. A topic is material if it matters in either of two directions: impact materiality (how the company affects people and the environment) or financial materiality (how a sustainability matter affects the company's own value). The double materiality assessment determines which ESRS topics — and therefore which datapoints — a company must report. Everything downstream, including the SAC model's scope, flows from it.

How the ESRS are structured

The ESRS comprise two cross-cutting standards — ESRS 1 (general requirements) and ESRS 2 (general disclosures) — plus topical standards across three pillars: Environmental (E1 Climate change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity, E5 Resource use and circular economy), Social (S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users) and Governance (G1 Business conduct). The most data-heavy and most modelled is ESRS E1, which requires greenhouse-gas emissions across Scopes 1, 2 and 3, plus energy consumption, a transition plan and reduction targets.

The 2026 reality: what the Omnibus reform changed

Anyone building a CSRD model in 2026 must know that the rules were significantly reshaped. The Omnibus I reform — Directive (EU) 2026/470, in force from March 2026 — narrowed scope and simplified the standards, while keeping the core intact. Three changes matter most: scope now centres on EU companies with more than 1,000 employees and over €450 million net turnover (cutting the number of in-scope companies sharply); the "stop-the-clock" directive postponed Wave 2 reporting by two years, so those companies' first reports move to 2028 (covering FY2027); and EFRAG's simplified ESRS cut the number of datapoints substantially, with the final delegated act expected around mid-2026. What did not change: double materiality remains mandatory, the disclosure obligation persists, and the substance — measure your footprint, set targets, show progress — is firmly in place. For a model builder the message is the one that recurs across regulation: build for the structure, because the parameters and dates move.

Scopes 1, 2 and 3

The GHG Protocol splits emissions into three scopes. Scope 1 is direct emissions from sources the company owns or controls (fuel combustion, company vehicles). Scope 2 is indirect emissions from purchased energy (electricity, heat, steam), reported on both a location-based and a market-based basis. Scope 3 is everything else in the value chain — purchased goods and services, business travel, use of sold products — and is usually by far the largest and hardest to collect. A credible E1 disclosure needs all three.

Structuring it in SAP Analytics Cloud

An emissions model behaves differently from the financial-ratio models for Basel III or Solvency II: emissions are additive, so SUM is usually right — but the intensity ratios and the Scope 2 dual basis introduce the same "calculate, don't sum" discipline.

Dimensions

Five dimensions carry most E1 reporting: Emission scope (Scope 1, 2, 3), GHG category / activity (the 15 Scope 3 categories, fuel types, energy sources), Site / entity (facility, country, legal entity), Period, and Version (Actual, baseline, target trajectory and scenarios). The Scope and Category dimensions are what let you show the footprint as a breakdown auditors and stakeholders can follow.

Measures: activity data × emission factor

Emissions are rarely measured directly — they are computed as activity data × emission factor (litres of fuel × kgCO₂e per litre, kWh × grid factor). Model activity data and emission factors as separate measures and make emissions a calculated measure. That keeps factors updatable in one place when methodologies change, and it makes every number traceable back to a source — exactly the evidence CSRD assurance looks for.

Aggregation: where the discipline bites

Tonnes of CO₂e SUM cleanly across scopes, sites and time — that part is simple. But intensity metrics (emissions per €m revenue, per unit produced, per FTE) are ratios: they must be calculated measures computed at the display level, never stored and then averaged across sites. Averaging an intensity across facilities of different sizes is a classic error that produces a plausible, wrong number. The same care applies to the Scope 2 location-based vs market-based figures: hold them as distinct measures (or versions) so they are never accidentally added together. We cover the underlying rule in choosing the right aggregation in SAC.

Targets and trajectories

E1 is not just a snapshot of last year's footprint — it requires a transition plan with reduction targets. The Version dimension is how the model holds the baseline year, the Actual, and the target trajectory (for example a science-based path to a percentage cut by 2030), letting the dashboard show the gap to target at any level. This is the Actual / Budget / Forecast pattern from using the Version dimension in SAC Planning, applied to carbon instead of cash.

A worked mini-example

A site burns 100,000 litres of diesel (Scope 1) at a factor of 2.68 kgCO₂e per litre → 268 tonnes. It buys 2,000,000 kWh of electricity (Scope 2) at a grid factor of 0.20 kgCO₂e per kWh → 400 tonnes location-based. Scope 1 + 2 = 668 tonnes. If the entity's revenue is €40m, the emissions intensity is 668 ÷ 40 = 16.7 tCO₂e per €m. Now add a second site and the absolute emissions SUM correctly; but the group intensity must be re-derived as total emissions ÷ total revenue, not the average of the two site intensities — model it as a calculated measure and it is always right.

Common mistakes to avoid

• Averaging intensities. Emissions intensity is a ratio — total emissions ÷ total revenue at the display level, never the average of site intensities.
• Hard-coding emissions. Compute emissions from activity data × emission factor so factors stay updatable and figures stay traceable.
• Merging Scope 2 bases. Keep location-based and market-based as distinct measures so they are never summed.
• Forgetting Scope 3. It is usually the largest share; a footprint without it is not E1-compliant.
• No baseline version. Without a baseline and target trajectory the model cannot show progress against the transition plan.

Where this fits

ESG reporting increasingly sits next to financial regulation — banks fold ESG risk into their Basel III frameworks, and the "structure once, calculate ratios live" discipline is the same one that governs Solvency II and IFRS 17. For a structured starting point, our carbon footprint template already separates scopes, activity data and factors, and the verified & maintained regulatory kit adds the intensity measures and an import guide.

Sources

CSRD — Directive (EU) 2022/2464; the ESRS adopted by the European Commission on EFRAG’s advice; the Omnibus reform — Directive (EU) 2026/470 — and the "stop-the-clock" Directive (EU) 2025/794; GHG Protocol for the scope definitions. The simplified ESRS and scope thresholds are still being finalised through 2026 — always check the current EUR-Lex and EFRAG texts for the provisions in force.