Should CSRD compliance be managed as a project or an ongoing process?

Both. Run the start as a project: the gap analysis, the double materiality assessment and the first report need a plan, milestones and a deadline. After that, CSRD becomes an ongoing process, with data owners, controls and an annual reporting cycle built into how the business runs, much like financial reporting.

CSRD compliance should be managed as both a project and an ongoing process, not one or the other. The initial setup, gap analysis, and first report require structured project management with clear milestones and deadlines. But once that foundation is in place, the real work shifts to embedding sustainability data collection and reporting into how your organization operates every year.

This distinction matters more than it might seem. Organizations that treat CSRD purely as a one-time project tend to scramble each reporting cycle, while those that build continuous processes find each subsequent report significantly easier to produce. Understanding exactly where that line falls — and how to manage both sides of it — is what the sections below are designed to help with.

What’s the difference between managing CSRD as a project vs. a process?

Managing CSRD as a project means treating it as a defined, time-bound initiative with a start date, an end date, and a deliverable — typically the sustainability report. Managing it as an ongoing process means treating CSRD reporting as a continuous organizational function, similar to financial reporting, that runs year-round and improves over time. The core difference is whether compliance stops when the report is filed or continues between reporting cycles.

A project mindset tends to focus on outputs: gather the data, produce the report, submit it, and consider it complete. A process mindset focuses on the underlying infrastructure — data systems, internal responsibilities, materiality assessments, and stakeholder engagement — that must function consistently regardless of where the organization sits in the reporting calendar.

Neither approach is entirely wrong on its own, but relying exclusively on one creates real problems. Organizations that handle CSRD most effectively combine both, applying project management to specific deliverables and process thinking to everything that must run continuously in the background. To understand why balance matters, it helps to look at what goes wrong when organizations default entirely to the project model.

Why does the project-only approach to CSRD fall short?

A project-only approach to CSRD compliance falls short because the Corporate Sustainability Reporting Directive requires organizations to track, measure, and disclose sustainability impacts that evolve throughout the year, not just at reporting time. If data collection only begins when the project kicks off, the information needed for a credible report will either be absent or insufficiently reliable to meet ESRS requirements.

There are several specific ways this plays out in practice:

• Data gaps accumulate between cycles. Sustainability metrics such as energy consumption, supply chain emissions, and workforce indicators must be tracked continuously. Beginning data collection a few months before the report deadline means working backwards to reconstruct information that should have been captured in real time.
• Double Materiality Assessments require ongoing input. The DMA is not a checkbox to be completed once. It involves stakeholder engagement and a genuine understanding of how your business both affects and is affected by sustainability issues — both of which evolve as your business changes.
• Regulatory requirements themselves keep shifting. The CSRD landscape has changed significantly. The Omnibus I directive (EU 2026/470) raised the thresholds to companies with more than 1,000 employees and more than €450 million in net turnover. On 3 July 2026, the European Commission adopted revised ESRS that reduce mandatory data points by over 60% and are expected to lower reporting costs by more than 30% per company. An organization treating CSRD as a closed project will have no one actively monitoring these developments between report cycles.
• Assurance requirements demand audit-ready documentation. CSRD reports require external assurance. Auditors need a clear, contemporaneous evidence trail — not a retrospective reconstruction of data assembled under deadline pressure.

Taken together, these gaps reveal a fundamental mismatch between what the project-only approach delivers and what CSRD actually demands. When the next reporting cycle arrives, the organization finds itself starting from scratch all over again. Knowing which parts of the process genuinely call for a project structure — and which do not — is the first step toward breaking that cycle.

Which parts of CSRD compliance genuinely need a project structure?

Several components of CSRD compliance genuinely benefit from a project structure because they are discrete, time-bound, and require coordinated effort across multiple teams or workstreams. These are the areas where a defined scope, clear ownership, and structured milestones determine whether the output is coherent or chaotic.

Initial gap analysis and readiness assessment

Before an organization can report under CSRD, it must assess where it currently stands relative to ESRS requirements. This is a well-suited project: it has a clear starting point, a defined deliverable, and a logical endpoint. The gap analysis maps existing data, processes, and disclosures against what CSRD requires, and the output directly informs every subsequent decision.

First-year report production

The first sustainability report under CSRD is the most complex to produce. It involves establishing reporting boundaries, completing the Double Materiality Assessment, selecting applicable ESRS disclosures, and producing a document that meets external assurance requirements. All of this benefits from a project plan with milestones, assigned responsibilities, and a firm deadline. Subsequent reports become substantially more manageable once the underlying infrastructure is in place.

System and process implementation

Building the data collection systems, internal workflows, and governance structures needed to support ongoing CSRD reporting is also project work. It is finite, requires cross-functional coordination, and has a clear end state: a functioning reporting infrastructure capable of running year-round without triggering a crisis at each cycle.

The common thread across all three is that they involve building something new. Once built, the ongoing operation of that infrastructure transitions from project management to process management — which raises an important question about how that handoff actually works in practice.

How do organizations transition CSRD from a project to an ongoing process?

Organizations transition CSRD from a project to an ongoing process by embedding sustainability data collection, governance, and review into existing business rhythms, rather than treating them as separate annual initiatives. The transition is complete when CSRD reporting no longer feels like a special project but instead functions as a standard part of how the organization operates — comparable to how financial reporting is managed.

In practical terms, several things must happen for this shift to take hold:

• Data collection becomes routine. Rather than gathering sustainability data in a rush before reporting deadlines, teams collect and validate it on a regular cadence — monthly or quarterly. This keeps data current and audit-ready throughout the year, reducing both the volume and urgency of work at reporting time.
• Internal ownership is formalized. A designated individual or working group holds explicit accountability for CSRD compliance year-round, not solely during report production. This might be a sustainability manager, a reporting lead, or a cross-functional working group with a clearly defined mandate and decision-making authority.
• Materiality assessments are reviewed on a structured cycle. The Double Materiality Assessment is not a one-time exercise. As business operations, stakeholder expectations, and the regulatory environment evolve, the assessment must be revisited. Incorporating this into an annual review cycle prevents the assessment from becoming outdated and ensures disclosures remain aligned with actual material impacts and risks.
• Regulatory monitoring is ongoing. The CSRD framework continues to develop. The revised ESRS adopted in July 2026 are still subject to parliamentary scrutiny, and further changes remain possible. Staying current with these developments requires someone actively tracking them throughout the year, not only when a new report is approaching.

The transition does not occur at a single moment — it happens gradually as each component of the reporting infrastructure is absorbed into normal operations. The clearest indicator that an organization has made the shift is when annual report production feels like a structured compilation exercise rather than an urgent data-gathering effort. Central to making that shift work is having the right internal ownership in place from the start.

Who should own CSRD compliance inside an organization?

CSRD compliance should be owned by a designated sustainability or ESG lead who holds cross-functional authority and a direct line to senior leadership. No single department can own it in isolation, because CSRD intersects with finance, HR, operations, legal, and procurement simultaneously. What matters most is that one individual or function carries explicit accountability for the overall reporting process — not merely for their own contribution to it.

In practice, ownership structures vary depending on organizational size and maturity. Larger organizations with dedicated sustainability functions often assign a Chief Sustainability Officer or Head of ESG Reporting as the primary owner, supported by working groups across departments that contribute data and analysis. Smaller organizations in scope — now limited to those with more than 1,000 employees and more than €450 million in net turnover under the revised thresholds — may assign ownership to a finance or legal director who coordinates with sustainability expertise brought in as needed.

What commonly goes wrong is when CSRD ownership is distributed without a clearly identified lead. A designated owner must be empowered to make decisions, resolve conflicts between competing priorities, and ensure the process remains on track between reporting cycles — not only during them. Even with strong internal ownership, however, there are situations where the right move is to supplement internal capacity with targeted external expertise.

When does it make sense to bring in external CSRD expertise?

It makes sense to bring in external CSRD expertise when your internal team lacks the specialized knowledge to handle specific reporting requirements, when the workload exceeds internal capacity, or when you are navigating a significant change — such as your first report, a major regulatory update, or a new business scope that affects your disclosures. External CSRD specialists bring a depth of knowledge that generalist internal teams rarely have the bandwidth to develop.

It is worth being precise about what “external expertise” means in this context, because CSRD reporting draws on genuinely distinct skill sets. A CSRD reporting expert with detailed knowledge of ESRS is not the same as a sustainability strategist or a Scope 3 emissions specialist. Depending on your specific gaps, you may need someone who can lead the Double Materiality Assessment, someone who understands the assurance process and can prepare audit-ready documentation, or someone who can translate the revised ESRS requirements into practical changes to your data collection systems.

External support is also warranted when the regulatory landscape shifts significantly. The revised ESRS adopted in July 2026 reduce mandatory data points substantially and introduce new reporting flexibilities, and assessing how those changes affect your specific obligations requires someone who tracks these developments closely. The timing of that engagement matters too — bringing in a specialist during the gap analysis phase or ahead of the first report is far more effective than seeking help when a deadline is already imminent, since early involvement allows the expert to shape the process rather than intervene to rescue it.

Ready to get the right CSRD support in place?

Whether you are building your CSRD reporting infrastructure for the first time, transitioning from a project-based approach to something more sustainable, or navigating the implications of the revised ESRS, having the right expertise available makes a measurable difference. The challenge is identifying someone with the specific knowledge your situation requires, at the right moment, without the overhead of a lengthy hiring process.

That’s exactly what we built Dazzle for. We match organizations with pre-screened CSRD reporting specialists who can step in quickly, whether you need project-based support for a specific deliverable or interim expertise to help embed CSRD into your ongoing operations. You can start working with the right expert within 48 hours, on a flexible basis that fits your timeline and budget. If you’re not sure where to start or what kind of support you need, get in touch with our team and we’ll help you figure it out.

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