CSRD reporting delays as strategic opportunities: Leveraging the breathing space in Nordic real estate.

The timeline for implementing the Corporate Sustainability Reporting Directive (CSRD) has been revised. The so-called wave 2 and 3 companies are getting something of a breather – a two-year delay to get things together. This is largely good news for companies that were to be affected by this legislation, as they now have more time to prepare and brace for the reporting requirements. 

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This article focuses on the real estate companies that meet the reporting thresholds and are poised to be affected by the CSRD (in its current form, because there are proposals in the works to change the scope). We will discuss how much more time you have and, most importantly, how you can use it to prepare better. 

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CSRD recap: What has changed?

The landmark sustainability reporting legislation and framework, CSRD, is supposed to be implemented in phases. Originally, the timeline was as follows:

In early 2024, the European Parliament and Council announced a two-year delay for certain companies under the ‘stop the clock’ directive. In short, while the first wave was implemented per schedule, the following two waves of implementation have been extended by two years. 

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The EU leadership cited the need for more time for these companies, which have not previously had any reporting requirements. This extension also enables EU organisations to work on the European Sustainability Reporting Standards (ESRS) for specific sectors and small and medium-sized enterprises (SMEs). This will result in more clarity for sector-specific requirements. 

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With this two-year delay, here’s what the updated timeline looks like: 

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What does the CSRD implementation delay mean?

The two-year delays in CSRD implementation for companies that weren’t reporting under the predecessor NFRD, including SMEs, mean the affected companies have more time on their hands to prepare. Lucky them. 

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In the meantime, the EU organisation responsible for creating sector-specific standards and any voluntary SME reporting frameworks can work to finalise those drafts. The gist is that this two-year delay is very much needed and can be beneficial for both authorities and companies that are required to report. 

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Since CSRD calls for sweeping reporting standards, companies in EU countries may need to set up processes for collecting and reporting data (including that from partners and suppliers). The actual data points to be reported depend on the double materiality analysis, which is part of the reporting standards (ESRS). Still, there may be a lot of data to gather and sort. 

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Companies should use this extra time strategically to conduct double materiality assessments, map their value chains, identify data gaps, and develop strong internal systems for data collection and reporting, so that when those two years are up, they’re fully prepared and ready to report. 

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How can Nordic real estate leverage more time for CSRD implementation?

In the context of Nordic real estate companies with various assets in their portfolio, the two-year delay in CSRD reporting presents opportunities to get things right. 

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Here’s how:

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Tighten ESG data flows and systems

A primary focus for Nordic real estate companies should be to assess and improve their current environmental, social, and governance (ESG) data. This can involve mapping and cleaning existing data sources, like granular energy consumption and emissions data or insights(for example, tenant energy consumption, which would be an indirect but still important data point).

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To collect and process all this ESG-related data from your assets, you’ll need to invest in advanced digital tools and APIs for automated data collection (comundo is exactly that kind of solution for energy data collection). You may also need to invest in comprehensive ESG software if your company's carbon footprint goes beyond simple energy consumption. 

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But most importantly, you must develop audit-ready processes that are aligned with double materiality principles. This will ensure that both financial materiality and impact materiality are captured and reported. This proactive approach will lay a strong, verifiable foundation for future sustainability reporting.

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Engage internal and external stakeholders early

Beyond technical data management, stakeholders are also a key part of the equation. That can include a number of parties, like your employees, lessees/tenants, and vendors. Chances are that you might need their participation to get ample data for reporting. 

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So, internally, create ESG literacy, for example, workshops for asset managers and operations staff. You may also need to dedicate personnel within your organisation to oversee all things ESG. 

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Externally, collaborate with tenants and inform them of your liabilities to report environmental data, and that their consumption data may need to be reported. In cases where you might not have direct access to energy data (because tenants have access), this disclosure and transparency can come in handy for creating processes that bring that data into the fold. 

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Similarly,  involve supply chain partners in Scope 3 emissions tracking for a comprehensive and accurate carbon footprint.

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Pro tip: Start mock reporting a year or two early to get in the groove and see which areas bring struggles and which you’re able to ace. 

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Drive portfolio-level sustainability improvements

CSRD also requires companies to disclose what they’re doing to align with the carbon-neutral transition the EU is on the trajectory for. What that means is that you can’t simply report emissions; you also need to show any initiatives you’re taking to mitigate them. 

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This extended timeframe provides plenty of time to drive significant portfolio-level sustainability improvements that go beyond mere compliance. You can integrate EU Taxonomy-aligned goals directly into their retrofit planning, setting, and diligently tracking science-based targets at the individual building level. 

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With renovations, you can improve the energy performance of your assets (again, data will be very helpful here). That’s good optics as far as reporting is concerned, but also great for your bottom line. And if you want to go all the way, perhaps get your assets one of those green building certifications, like the Nordic Swan Ecolabel.  

Action plan and timeline

Need even more solid guidance? Here’s your game plan for the next two to three years: 

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Short-term priorities (Next 6–12 months)

• Run a CSRD gap analysis: Assess your current ESG disclosures, governance structure, and data quality against CSRD requirements
  
• Initiate stakeholder materiality assessments: Begin structured engagement with tenants, investors, local governments, and employees to identify material ESG issues and set reporting priorities
  
• Map ESG data infrastructure: Identify which systems hold ESG data, and determine where consolidation or upgrades are needed
  
• Set internal accountability: Assign ESG ownership to finance, risk, and operational teams (or even a dedicated sustainability team)
  
  

Medium-term priorities (12–24 months)

• Implement or upgrade ESG data platforms: Invest in tools that support CSRD-ready reporting
  
• Pilot a CSRD-aligned reporting cycle: Run a mock disclosure exercise in 2026 to surface weaknesses and establish timelines for narrative preparation, data validation, and assurance
  
• Engage auditors early: Involve assurance providers to review your ESG processes and understand your data architecture
  
  

Long-term goals (2026–2027)

• Finalise assurance and governance procedures: Build clear workflows for sustainability oversight, audit committee engagement, and board-level ESG risk evaluation
  
• Refine communication strategy: Use voluntary or pre-regulatory reports in 2026 to establish your voice in the market and provide early signals to capital partners
  
• Submit a complete, audit-ready CSRD report: Enter 2027 with confidence by treating the delay as a pre-season

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Turn compliance into a competitive edge!

Regulations shouldn’t be seen as a roadblock to growth, but as an opportunity. And now you have both the opportunity and time to turn ESG reporting into a strategy for making viable changes to your portfolio and solidify data gathering and processing. 

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comundo can be the perfect addition to your tech stack, as you prep to begin reporting for CSRD in the coming years. It can automate the collection, refinement, and analysis of energy data, which is key to the ESG performance of any real estate holdings in the Nordic region. 

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Learn more about comundo and its proprietary technology for streamlining energy data in the Danish (and Nordic) markets!

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