ESG Gap Analysis Report — Heembouw B.V.
Framework: CSRD / ESRS 2 (General) · ESRS E1 (Climate Change) · ESRS S1 (Own Workforce)
Company: Heembouw B.V. (Heembouw B.V.)
Country: NL | NACE: 41.20
Employees: 200 FTE | Revenue: €38.0M
Reporting Year: FY2024
Report ID: gap_heembouw_pilot_001_1774608251022
Generated: 27 March 2026
This gap analysis is prepared against CSRD / ESRS disclosure requirements, covering ESRS 2 cross-cutting governance and strategy disclosures, ESRS E1 (Climate Change), and ESRS S1 (Own Workforce — construction sector). It is based on the company profile provided and does not constitute legal advice. Engage a qualified sustainability consultant for full CSRD readiness assessment.
1. CSRD Applicability
Status: ⚠️ Likely In Scope (supply chain pressure)
This company is currently below CSRD thresholds (200 FTE, €38.0M revenue). Mandatory CSRD reporting does not apply yet.
Threshold Check
| Criterion | Your Value | Threshold | Status |
|---|---|---|---|
| Employees (FTE) | 200 | > 250 | ❌ Below |
| Annual Revenue | €38.0M | > €40M | ❌ Below |
| Balance Sheet Total | €18.0M | > €20M | ❌ Below |
No mandatory reporting year identified under current thresholds.
⚠️ Supply chain pressure: Large construction contractors (Scope 1 CSRD reporters) are required to disclose Scope 3 Category 1 emissions, which includes materials and services purchased from companies like yours. You will increasingly receive data requests from your clients. Proactive ESG reporting is strongly recommended to protect and grow revenue with large clients.
Note: The EU Omnibus simplification proposal (COM/2025/81, published Feb 2025) proposes raising the large company threshold to >1,000 employees and removing mandatory Scope 3 for most companies. This has NOT been enacted as of March 2026 — current CSRD thresholds apply.
2. Compliance Readiness Summary
Overall Readiness Score: 0/100 [░░░░░░░░░░]
| Status | Count |
|---|---|
| ✅ Met | 0 |
| ⚠️ Partial | 0 |
| ❌ Missing | 23 |
| ➖ Not Applicable | 2 |
| Total disclosures assessed | 25 |
🔴 7 critical gaps require immediate attention before any CSRD filing.
🟠 8 high-priority gaps should be addressed within the next reporting cycle.
3. Double Materiality — Topic Screening (Construction Sector)
Based on [EFRAG IG1 Implementation Guidance on Materiality Assessment](https://www.efrag.org/en/projects/esrs-implementation-guidance/ig-1-materiality-assessment). Full double materiality assessment (DMA) has not yet been conducted — see gap SBM-3. The table below shows construction-sector pre-flags from EFRAG IG1 to guide DMA scoping.
| ESRS Topic | Subject | Impact Materiality | Financial Materiality | Pre-flag (Construction) |
|---|---|---|---|---|
| ESRS E1 | Climate Change | High (carbon emissions, embodied carbon) | High (carbon pricing, transition costs, climate risk) | Presumptively material |
| ESRS E2 | Pollution | High (NOx/PM, site dust, chemical runoff) | Medium (regulatory fines, site remediation) | Screen required |
| ESRS E3 | Water & Marine Resources | Medium (site dewatering, groundwater) | Low–Medium | Screen required |
| ESRS E4 | Biodiversity & Ecosystems | High (land use, soil sealing, habitat) | Medium (Nature Restoration Law compliance) | Likely material |
| ESRS E5 | Resource Use & Circular Economy | High (35% of EU waste is C&D waste) | Medium (material costs, circular economy transition) | Likely material |
| ESRS S1 | Own Workforce | Critical (highest EU sector fatality rate) | High (liability, retention, client pre-qual) | Presumptively material |
| ESRS S2 | Workers in Value Chain | High (subcontractor H&S, migrant labour) | Medium | Screen required |
| ESRS S3 | Affected Communities | Medium (noise, traffic, site impacts) | Low–Medium | Screen required |
| ESRS S4 | Consumers & End Users | Low (building users; product safety) | Low | Screen required |
| ESRS G1 | Business Conduct | Medium (anti-bribery, procurement) | Medium | Screen required |
Next step: Conduct a full DMA covering impact and financial materiality for each topic, with stakeholder engagement as required by [EFRAG IG1](https://www.efrag.org/en/projects/esrs-implementation-guidance/ig-1-materiality-assessment). Conclude which topics are material and document the IRO identification process for each.
4. Emissions & Energy Data
No emissions data available for this profile. Scope 1, 2, and 3 data collection is required before an emissions inventory can be presented.
4.4 Scope 3 Category Coverage and Exclusions (EFRAG IG3)
Per EFRAG IG3 Implementation Guidance on Datapoints, companies must list all Scope 3 categories assessed and explain exclusions. The table below documents the current status for FY2024:
| Cat | Description | Construction Materiality | FY2024 Status | Justification |
|---|---|---|---|---|
| 1 | Purchased goods & services (embodied carbon) | Highest — 80–90% of total GHG | Not measured | Top-5-projects BOM only; full inventory outstanding |
| 2 | Capital goods (owned plant, equipment) | Medium — heavy machinery, scaffolding | Not measured | Excluded Year 1 — below materiality threshold; to screen Year 2 |
| 3 | Fuel & energy related (upstream) | Low | Not measured | Excluded — relatively small for Dutch operations |
| 4 | Upstream transportation & distribution | High — logistics to site | Not measured | To be measured using [GLEC Framework v3](https://www.smartfreightcentre.org/en/our-programs/global-logistics-emissions-council/) |
| 5 | Waste generated in operations (C&D waste) | High — construction = 35% of EU waste | Not measured | Excluded Year 1; included in E5 roadmap |
| 6 | Business travel | Low | Not measured | Excluded — below materiality threshold |
| 7 | Employee commuting | Low | Not measured | Excluded — company size <250 FTE |
| 8 | Upstream leased assets | Not applicable | N/A | Company does not lease upstream assets |
| 9 | Downstream transportation | Not applicable | N/A | Subcontractor — no downstream distribution |
| 10 | Processing of sold products | Not applicable | N/A | No intermediate products sold |
| 11 | Use of sold products (embodied in buildings) | High for developers | Not applicable | Subcontractor — does not own finished buildings |
| 12 | End-of-life treatment of sold products | Medium for developers | Not applicable | Subcontractor — end-of-life responsibility lies with building owner |
| 13 | Downstream leased assets | Not applicable | N/A | No downstream leased assets |
| 14 | Franchises | Not applicable | N/A | No franchise operations |
| 15 | Investments | Not applicable | N/A | No investment portfolio |
[EFRAG IG3](https://www.efrag.org/en/projects/esrs-implementation-guidance/ig-3-list-of-esrs-datapoints) note: Exclusions above reflect Year 1 reporting scope. All excluded categories must be rescreened annually and included if they become material. Cat 1 full inventory (all projects, all material types) and Cat 4 are the priority for Year 2.
5. ESRS Gap Analysis — Full Detail
Disclosures are ordered by priority. Covers ESRS E1 (Climate Change), ESRS 2 cross-cutting governance/strategy disclosures, ESRS S1 (Own Workforce — construction sector), ESRS E4 (Biodiversity), and ESRS E5 (Resource Use). Each item references the specific ESRS clause.
ESRS 2 SBM-3: Material IROs from strategy and business model
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 44–48 |
| CSRD Article | CSRD Art. 19a(2)(a) |
| Effort to Close | weeks |
Assessment: No double materiality assessment has been conducted. This is a prerequisite for all other ESRS disclosures — it determines which sustainability topics are material and therefore which disclosures are mandatory for your company. Without it, you cannot reliably determine your CSRD reporting scope.
Recommended action: Conduct a double materiality assessment covering both impact materiality (company's impact on environment/society) and financial materiality (sustainability risks to business). For construction companies, climate change (E1) and biodiversity (E4) are almost always material. Engage a sustainability consultant for a structured DMA process.
Phase-in / note: Required from first CSRD reporting year. No phase-in exemption.
ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 1
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 44(a), 45–47 |
| CSRD Article | CSRD Art. 19a(2)(e) |
| Effort to Close | days |
Assessment: Scope 1 (direct) GHG emissions have not been measured. This is the most fundamental climate disclosure — mandatory from Year 1 with no phase-in. For construction companies, Scope 1 includes diesel plant & equipment, company vehicles, site generators, and gas heating. Methodology: GHG Protocol Corporate Standard, using DEFRA 2025 or IPCC AR6 emission factors.
Missing data elements:
- Diesel consumption (litres) from plant, vehicles, generators
- Natural gas consumption (kWh or m³) from site facilities/offices
- Refrigerant top-up records (HFCs from A/C systems)
Recommended action: Collect diesel consumption data from plant hire records and fuel purchase invoices. Collect natural gas consumption from site facilities. Apply DEFRA 2025 emission factors (e.g. diesel: 2.68 kgCO2e/litre). Use our emissions calculation engine to produce a traceable Scope 1 figure.
Phase-in / note: Mandatory from FY2024 for large PIEs, FY2025 for all large companies. No Scope 1 phase-in.
ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 2 (location-based)
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 44(b), 48–50 |
| CSRD Article | CSRD Art. 19a(2)(e) |
| Effort to Close | days |
Assessment: Scope 2 (indirect energy) emissions have not been measured using the location-based method. ESRS E1-6 requires both location-based and market-based Scope 2 disclosures. Location-based uses national grid average emission factors (Netherlands: ~0.45 kgCO2e/kWh as of 2023).
Missing data elements:
- Electricity consumption (kWh) from all site facilities, offices, depots
- District heating/cooling consumption (if applicable)
Recommended action: Collect electricity consumption (kWh) from utility invoices for all offices, depots, and controlled site facilities. Apply the national grid emission factor for the Netherlands (CBS/Tennet annual factor). Use our Scope 2 calculator to produce a traceable result.
ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 3
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 44(c), 51–56 |
| CSRD Article | CSRD Art. 19a(2)(e) |
| Effort to Close | weeks |
Assessment: No Scope 3 data exists. For construction companies, Scope 3 typically represents 85–95% of total GHG footprint — primarily Category 1 (embodied carbon in building materials: concrete, steel, timber) and Category 4 (logistics). Without Scope 3, your climate disclosure is materially incomplete. ESRS E1-6 requires disclosure of all material Scope 3 categories.
Missing data elements:
- Cat 1: Purchased goods (embodied carbon in building materials — highest exposure for construction)
- Cat 4: Upstream transportation (materials logistics to site)
Recommended action: Prioritise Category 1 (purchased goods): collect a bill-of-materials for the top 5 projects by value. Apply ICE Database v4.1 emission factors (concrete: 0.095 kgCO2e/kg; structural steel: 1.46 kgCO2e/kg; timber: -0.45 kgCO2e/kg). Use our Scope 3 Cat 1 calculator for a traceable inventory. Then address Cat 4 (transport) using GLEC Framework factors.
Phase-in / note: Phase-in: first-year reporters may omit Scope 3 in Year 1, but must include from Year 2. This phase-in is under review in the Omnibus proposal.
ESRS 2 GOV-1: Role of Administrative, Management and Supervisory Bodies
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 21–24 |
| CSRD Article | CSRD Art. 19a(2)(a) |
| Effort to Close | weeks |
Assessment: The board or supervisory body has no defined sustainability oversight role. ESRS 2 GOV-1 requires disclosure of how the highest governance body oversees sustainability matters, including climate and other material topics. For construction companies where E1 and S1 are material, board oversight of climate and H&S is a CSRD prerequisite.
Recommended action: Assign sustainability oversight responsibility to a specific board committee or board member. Document the scope of oversight (which sustainability topics), the reporting cadence to the board, and the expertise available at board level. This can be formalised in board terms of reference.
ESRS 2 IRO-2: Disclosure Requirements in ESRS Covered by the Undertaking's Sustainability Statement
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 114–116 |
| Effort to Close | days |
|---|
Assessment: No ESRS disclosure requirements index exists. IRO-2 requires a table mapping all applicable ESRS disclosure requirements to the corresponding section in the sustainability statement (or explaining omissions). This is mandatory for CSRD-compliant filings and serves as a navigation index for auditors and stakeholders.
Recommended action: Prepare a disclosure index table listing all applicable ESRS disclosure requirements (derived from your materiality assessment), the corresponding section/page in your sustainability report, and a note for any required-but-omitted datapoints with justification. This is typically the last section of a CSRD-compliant report.
ESRS S1-1: Policies Related to Own Workforce — Health & Safety
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🔴 Critical |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS S1, paragraphs 20–24 |
| Effort to Close | weeks |
|---|
Assessment: No formal health and safety policies are documented for own workforce. For construction companies, ESRS S1 health & safety disclosures are near-certain material — EU construction has the highest workplace fatality rate of any sector. ESRS S1-1 requires formal H&S policies covering all workers (employees and non-employees) and a description of the due diligence process for H&S risks.
Recommended action: Document a formal Health & Safety Policy signed by the CEO covering: (1) H&S objectives and KPIs, (2) risk assessment methodology for construction sites, (3) incident reporting process, (4) coverage of subcontractor workers. Align with Dutch Arbowet and ESRS S1 requirements.
Phase-in / note: Subject to materiality — near-certain material for construction sector.
ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 2 (market-based)
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 44(b), 48–50 |
| Effort to Close | days |
|---|
Assessment: Scope 2 market-based emissions have not been documented. Market-based method uses contractual instruments (Energy Attribute Certificates / Guarantees of Origin) to reflect the actual renewable energy content of purchased electricity. Both methods must be disclosed per ESRS E1-6.
Recommended action: Check whether your electricity contracts include Guarantees of Origin (GOs) or whether you have EAC/GOs. If not, report market-based at the residual mix factor for the Netherlands (~0.49 kgCO2e/kWh). Consider purchasing GOs to reduce market-based Scope 2 to near zero — this is a low-cost win.
ESRS E1-5: Energy Consumption and Mix
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 36–43 |
| CSRD Article | CSRD Art. 19a(2)(e) |
| Effort to Close | days |
Assessment: Energy consumption data (total energy, breakdown by fossil/renewable, energy intensity) has not been documented. ESRS E1-5 requires disclosure of total energy consumption (MWh), the renewable vs. fossil energy split, and an energy intensity ratio (e.g. MWh per €M revenue or MWh per FTE).
Missing data elements:
- Total energy consumption (MWh) by source type
- Renewable vs. fossil energy split (%)
- Energy intensity ratio (MWh/€M revenue or MWh/FTE)
Recommended action: Aggregate total energy consumption from: fuel purchase invoices (diesel, gas → convert to MWh using DEFRA conversion factors), electricity invoices (kWh → MWh), and any district heating bills. Calculate % renewable (if you have GOs for electricity). Compute intensity: total MWh ÷ revenue (€M).
ESRS E1-4: Targets Related to Climate Change Mitigation and Adaptation
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E1, paragraphs 33–35 |
| CSRD Article | CSRD Art. 19a(2)(d) |
| Effort to Close | months |
Assessment: No GHG reduction target has been set. ESRS E1-4 requires companies to disclose absolute GHG reduction targets, with base year, target year, and % reduction. SBTi (Science Based Targets initiative) alignment is encouraged but not mandatory. The absence of a target is itself a disclosure gap — you must explain why no target exists if climate is material.
Recommended action: Set an absolute GHG reduction target covering at least Scope 1+2. Ideally align with a 1.5°C pathway — consider SBTi's construction sector guidance (v5.3, Sep 2025). As a minimum, disclose your intention to set a target and the timeline. For the MVP demo, a stated goal is sufficient; formal SBTi validation can follow.
Phase-in / note: Subject to materiality. If climate is material (which it almost certainly is for construction), E1-4 disclosure is required.
ESRS E1-1: Transition Plan for Climate Change Mitigation
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 14–19 |
| CSRD Article | CSRD Art. 19a(2)(a) |
| Effort to Close | months |
Assessment: No climate transition plan exists. ESRS E1-1 requires a documented plan describing how the company will achieve its climate-related targets and transition to a climate-neutral economy by 2050, including decarbonisation levers and CapEx commitments. Phase-in: 3 years for first-time reporters to develop a full transition plan.
Recommended action: Develop a high-level transition roadmap covering: (1) where you are today (GHG baseline), (2) your 2030 and 2050 targets, (3) key decarbonisation actions (fuel switching, supply chain engagement, material substitution), (4) CapEx committed. This can start as a 2-page document and be expanded over time.
Phase-in / note: Phase-in: companies may explain they 'are in the process of developing a transition plan' for the first 3 reporting years per ESRS E1, paragraph 19.
ESRS 2 GOV-2: Information Provided to and Sustainability Matters Addressed by Undertaking's Bodies
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 25–28 |
| Effort to Close | weeks |
|---|
Assessment: Management has no defined sustainability role or reporting structure. ESRS 2 GOV-2 requires disclosure of how management-level bodies (CEO, CFO, ESG Director) are responsible for sustainability management, including reporting lines and decision-making authority.
Recommended action: Assign a named sustainability owner at management level (e.g. CFO, Operations Director). Define their responsibility for data collection, reporting, and implementation of sustainability actions. Document reporting lines to the board. For an SME, this can be a part-time role with a short written mandate.
ESRS 2 GOV-4: Statement on Due Diligence
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 32–33 |
| Effort to Close | weeks |
|---|
Assessment: No due diligence statement exists. ESRS 2 GOV-4 requires a statement on whether and how the company conducts due diligence on sustainability matters, aligned with the EU Corporate Sustainability Due Diligence Directive (CSDDD) framework. For construction companies, this covers supply chain H&S, environmental compliance at project sites, and subcontractor oversight.
Recommended action: Prepare a brief due diligence statement covering: (1) scope of due diligence (own operations + key suppliers), (2) process for identifying risks (supplier questionnaires, site audits), (3) how adverse impacts are addressed. Align with OECD Guidelines for Multinational Enterprises as a recognised international standard.
ESRS 2 SBM-1: Strategy, Business Model and Value Chain
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 40–43 |
| Effort to Close | weeks |
|---|
Assessment: Sustainability is not integrated in the documented business model or strategy. ESRS 2 SBM-1 requires description of how sustainability matters are reflected in the company's strategy, business model, and value chain — including significant relationships with customers, suppliers, and other stakeholders.
Recommended action: Add a sustainability section to the company's strategic plan or annual report narrative that explains: (1) how ESG risks are integrated in investment decisions, (2) sustainability commitments to clients (CSRD value chain pressure), (3) key supply chain relationships and their sustainability profile.
ESRS S1-14: Health and Safety Metrics — Injury Rates and Recordable Incidents
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟠 High |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS S1, paragraphs 88–93 |
| Effort to Close | weeks |
|---|
Assessment: Workplace injury and health & safety rate data is not documented. ESRS S1-14 requires Lost Time Injury Frequency Rate (LTIFR), number of recordable work-related accidents, fatalities, and days lost — separately for employees and non-employee workers (subcontractors). For construction, this is among the highest-priority S1 disclosures given the sector's fatality rate.
Recommended action: Implement an incident register tracking all work-related accidents, near-misses, and dangerous occurrences across own sites and subcontractor sites. Calculate LTIFR = (Lost time injuries × 1,000,000) / hours worked. Report separately for employees and non-employee workers (subcontractors). This data is also required for ISO 45001 and many client pre-qualification questionnaires.
Phase-in / note: Subject to materiality — near-certain material for construction.
ESRS E1-2: Policies Related to Climate Change Mitigation and Adaptation
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E1, paragraphs 20–22 |
| Effort to Close | weeks |
|---|
Assessment: No formal climate-related policies are documented. ESRS E1-2 requires disclosure of policies that address climate change mitigation (reducing GHG) and/or adaptation (managing climate risks). This includes the scope, whether the value chain is covered, and links to the company's overall strategy.
Recommended action: Draft a brief Climate and Sustainability Policy (1–2 pages) covering: commitment to GHG reduction, energy efficiency, responsible procurement, and climate risk management. Have it approved by the board/CEO and make it available on your website.
Phase-in / note: Subject to materiality assessment.
ESRS E1-3: Actions and Resources in Relation to Climate Change
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E1, paragraphs 23–28 |
| Effort to Close | weeks |
|---|
Assessment: No documented climate action plan with resource allocation exists. ESRS E1-3 requires companies to describe their concrete climate actions (e.g. switching to electric vehicles, procuring low-carbon materials, installing solar), the expected GHG reduction from each action, and the CapEx/OpEx allocated.
Recommended action: Create an action register tracking: (1) active decarbonisation initiatives, (2) expected GHG reduction per initiative, (3) budget allocated. Start with the top 3 actions — e.g. transitioning site machinery to HVO fuel, engaging top 5 material suppliers on EPDs, switching to renewable electricity.
Phase-in / note: Subject to materiality assessment.
ESRS E1-9: Anticipated Financial Effects from Material Physical and Transition Climate Risks
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Yes |
| ESRS Reference | ESRS E1, paragraphs 65–68 |
| CSRD Article | CSRD Art. 19a(2)(f) |
| Effort to Close | weeks |
Assessment: No physical or transition climate risk assessment has been conducted. ESRS E1-9 requires companies to disclose their exposure to physical risks (flooding, extreme heat, storms) and transition risks (carbon pricing, regulatory changes, market shifts), with anticipated financial effects quantified where possible. For construction in the Netherlands, flood risk and energy price volatility are particularly relevant.
Recommended action: Conduct a climate risk screening: (1) Map physical risks to your sites and operations using TCFD/TNFD frameworks — for NL, focus on flooding (sites below sea level), extreme heat (worker productivity), and storm damage. (2) Map transition risks: carbon pricing trajectory (EU ETS), low-carbon materials cost premium, client requirements. (3) Estimate financial exposure ranges. Start with a 1-page risk register.
Phase-in / note: Phase-in: financial quantification allowed to develop over 3 years for first-time reporters.
ESRS 2 SBM-2: Interests and Views of Stakeholders
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Yes |
| ESRS Reference | ESRS 2, paragraphs 44–48 |
| Effort to Close | weeks |
|---|
Assessment: No documented stakeholder engagement process exists for sustainability. ESRS 2 SBM-2 requires companies to describe how they identify and engage with stakeholders on sustainability matters, and how stakeholder views are incorporated into strategy and risk assessment.
Recommended action: Map your key stakeholder groups (clients, employees, subcontractors, financiers, local communities). Document how you currently engage with them on sustainability topics (e.g. client ESG questionnaires, employee surveys, supplier codes of conduct). This can be a 1-page stakeholder map with engagement method and frequency.
ESRS S1-6 / S1-7: Characteristics of Employees and Non-Employee Workers
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS S1, paragraphs 50–60 |
| Effort to Close | days |
|---|
Assessment: Workforce headcount broken down by gender and employment type is not available. ESRS S1-6 requires total number of employees by gender, contract type (permanent/temporary), and full-time/part-time status. S1-7 requires data on non-employee workers (subcontractors) in the value chain.
Recommended action: Extract headcount data from payroll/HR system: total employees by gender, permanent vs temporary, full-time vs part-time. For subcontractor workers (non-employee), collect from project management records. This data is typically already available in HR systems — it needs to be extracted and validated for the reporting year.
Phase-in / note: Subject to materiality.
ESRS E4: Biodiversity and Ecosystems — Not Yet Assessed
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E4, paragraphs 1–52 |
| Effort to Close | months |
|---|
Assessment: Biodiversity and ecosystem impacts have not been assessed by this tool. For construction companies, E4 is considered high-materiality: land use change, soil sealing, habitat disruption at project sites, and risks to protected species are inherent to the sector. The EU Nature Restoration Law (2024) further increases regulatory exposure. EFRAG IG1 identifies construction as a sector where biodiversity impact is presumptively material and must be screened before concluding non-materiality.
Recommended action: Conduct an E4 materiality screening: (1) identify all project sites near protected areas (Natura 2000, national parks), (2) assess soil sealing and land-take per project, (3) review Dutch Nature Conservation Act compliance per planning permission. Engage a biodiversity specialist for sites with potential habitat impacts. Document screening outcomes to support a materiality conclusion.
Phase-in / note: Subject to materiality — screening required from first reporting year. Construction sector: likely material per EFRAG IG1.
ESRS E5: Resource Use and Circular Economy — Not Yet Assessed
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟡 Medium |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E5, paragraphs 1–51 |
| Effort to Close | months |
|---|
Assessment: Resource use and circular economy disclosures have not been assessed by this tool. Construction is the largest source of waste in the EU (≈35% of total waste). ESRS E5 requires disclosure of material consumption by resource type, waste generated (hazardous/non-hazardous), construction and demolition waste recycling rate, and circular economy initiatives. Dutch Bouwakkoord targets 50% circular construction by 2030, making E5 disclosures increasingly expected by clients and financiers.
Recommended action: Conduct an E5 materiality screening: (1) quantify construction and demolition waste by type from project waste manifests, (2) document recycling/reuse rates from waste processor certificates, (3) identify top-5 material inputs by mass (concrete, steel, timber, aggregates), (4) review circular economy initiatives (prefabrication, material reuse, design for disassembly). Use output to support a materiality conclusion on E5.
Phase-in / note: Subject to materiality — high likelihood of materiality for construction. Screening required from first CSRD reporting year.
ESRS 2 GOV-3: Integration of Sustainability Performance in Incentive Schemes
| Field | Value |
|---|---|
| Status | ❌ Missing |
| Priority | 🟢 Low |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS 2, paragraphs 29–31 |
| Effort to Close | weeks |
|---|
Assessment: ESRS 2 GOV-3 requires disclosure of whether and how climate/sustainability performance metrics are linked to executive or management remuneration. Most construction companies currently have no such linkage — this must be stated explicitly, not just omitted.
Recommended action: Review management remuneration structures. Disclose whether sustainability KPIs are included. If not currently included, consider adding a qualitative ESG component to the next remuneration review cycle. This is a board-level governance matter.
Phase-in / note: Subject to materiality assessment.
ESRS E1-7: GHG Removals and Carbon Credits
| Field | Value |
|---|---|
| Status | ➖ N/A |
| Priority | 🟢 Low |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E1, paragraphs 57–59 |
| Effort to Close | days |
|---|
Assessment: ESRS E1-7 requires disclosure of GHG removals (from land use / LULUCF activities) and any carbon credits purchased. For most construction subcontractors with no forestry/land assets, this disclosure is 'not applicable'. If carbon credits are purchased, they must be disclosed separately from emission reductions.
Recommended action: Confirm whether your company purchases carbon offsets or credits. If yes, document the standard (Gold Standard, VCS), amount (tCO2e), and project type. Clarify that these are not counted against your gross GHG reduction target (ESRS E1-6). If no credits/removals, a brief 'not applicable' statement in your report is sufficient.
ESRS E1-8: Internal Carbon Pricing
| Field | Value |
|---|---|
| Status | ➖ N/A |
| Priority | 🟢 Low |
| Mandatory | Subject to materiality |
| ESRS Reference | ESRS E1, paragraphs 60–64 |
| Effort to Close | days |
|---|
Assessment: Internal carbon pricing is not currently used. ESRS E1-8 only applies if the company uses an internal carbon price in its investment/decision-making. This is optional for most SMEs and mid-sized contractors.
Recommended action: If you do not use internal carbon pricing, include a brief statement in your report: 'The company does not currently use an internal carbon price.' This disclosure is only required if the company actively uses carbon pricing as a management tool.
6. Priority Action Plan
Based on the gap analysis above, the following actions are recommended in priority order:
🔴 Critical — Do First (prerequisite for CSRD filing)
1. ESRS 2 SBM-3: Conduct a double materiality assessment covering both impact materiality (company's impact on environment/society) and financial materiality (sustainability risks to business). For construction companies, climate change (E1) and biodiversity (E4) are almost always material. Engage a sustainability consultant for a structured DMA process.
2. ESRS E1-6: Collect diesel consumption data from plant hire records and fuel purchase invoices. Collect natural gas consumption from site facilities. Apply DEFRA 2025 emission factors (e.g. diesel: 2.68 kgCO2e/litre). Use our emissions calculation engine to produce a traceable Scope 1 figure.
3. ESRS E1-6: Collect electricity consumption (kWh) from utility invoices for all offices, depots, and controlled site facilities. Apply the national grid emission factor for the Netherlands (CBS/Tennet annual factor). Use our Scope 2 calculator to produce a traceable result.
4. ESRS E1-6: Prioritise Category 1 (purchased goods): collect a bill-of-materials for the top 5 projects by value. Apply ICE Database v4.1 emission factors (concrete: 0.095 kgCO2e/kg; structural steel: 1.46 kgCO2e/kg; timber: -0.45 kgCO2e/kg). Use our Scope 3 Cat 1 calculator for a traceable inventory. Then address Cat 4 (transport) using GLEC Framework factors.
5. ESRS 2 GOV-1: Assign sustainability oversight responsibility to a specific board committee or board member. Document the scope of oversight (which sustainability topics), the reporting cadence to the board, and the expertise available at board level. This can be formalised in board terms of reference.
6. ESRS 2 IRO-2: Prepare a disclosure index table listing all applicable ESRS disclosure requirements (derived from your materiality assessment), the corresponding section/page in your sustainability report, and a note for any required-but-omitted datapoints with justification. This is typically the last section of a CSRD-compliant report.
7. ESRS S1-1: Document a formal Health & Safety Policy signed by the CEO covering: (1) H&S objectives and KPIs, (2) risk assessment methodology for construction sites, (3) incident reporting process, (4) coverage of subcontractor workers. Align with Dutch Arbowet and ESRS S1 requirements.
🟠 High Priority — Address This Reporting Cycle
1. ESRS E1-6: Check whether your electricity contracts include Guarantees of Origin (GOs) or whether you have EAC/GOs. If not, report market-based at the residual mix factor for the Netherlands (~0.49 kgCO2e/kWh). Consider purchasing GOs to reduce market-based Scope 2 to near zero — this is a low-cost win.
2. ESRS E1-5: Aggregate total energy consumption from: fuel purchase invoices (diesel, gas → convert to MWh using DEFRA conversion factors), electricity invoices (kWh → MWh), and any district heating bills. Calculate % renewable (if you have GOs for electricity). Compute intensity: total MWh ÷ revenue (€M).
3. ESRS E1-4: Set an absolute GHG reduction target covering at least Scope 1+2. Ideally align with a 1.5°C pathway — consider SBTi's construction sector guidance (v5.3, Sep 2025). As a minimum, disclose your intention to set a target and the timeline. For the MVP demo, a stated goal is sufficient; formal SBTi validation can follow.
4. ESRS E1-1: Develop a high-level transition roadmap covering: (1) where you are today (GHG baseline), (2) your 2030 and 2050 targets, (3) key decarbonisation actions (fuel switching, supply chain engagement, material substitution), (4) CapEx committed. This can start as a 2-page document and be expanded over time.
5. ESRS 2 GOV-2: Assign a named sustainability owner at management level (e.g. CFO, Operations Director). Define their responsibility for data collection, reporting, and implementation of sustainability actions. Document reporting lines to the board. For an SME, this can be a part-time role with a short written mandate.
6. ESRS 2 GOV-4: Prepare a brief due diligence statement covering: (1) scope of due diligence (own operations + key suppliers), (2) process for identifying risks (supplier questionnaires, site audits), (3) how adverse impacts are addressed. Align with OECD Guidelines for Multinational Enterprises as a recognised international standard.
7. ESRS 2 SBM-1: Add a sustainability section to the company's strategic plan or annual report narrative that explains: (1) how ESG risks are integrated in investment decisions, (2) sustainability commitments to clients (CSRD value chain pressure), (3) key supply chain relationships and their sustainability profile.
8. ESRS S1-14: Implement an incident register tracking all work-related accidents, near-misses, and dangerous occurrences across own sites and subcontractor sites. Calculate LTIFR = (Lost time injuries × 1,000,000) / hours worked. Report separately for employees and non-employee workers (subcontractors). This data is also required for ISO 45001 and many client pre-qualification questionnaires.
🟡 Medium Priority — Address Next Cycle
1. ESRS E1-2: Draft a brief Climate and Sustainability Policy (1–2 pages) covering: commitment to GHG reduction, energy efficiency, responsible procurement, and climate risk management. Have it approved by the board/CEO and make it available on your website.
2. ESRS E1-3: Create an action register tracking: (1) active decarbonisation initiatives, (2) expected GHG reduction per initiative, (3) budget allocated. Start with the top 3 actions — e.g. transitioning site machinery to HVO fuel, engaging top 5 material suppliers on EPDs, switching to renewable electricity.
3. ESRS E1-9: Conduct a climate risk screening: (1) Map physical risks to your sites and operations using TCFD/TNFD frameworks — for NL, focus on flooding (sites below sea level), extreme heat (worker productivity), and storm damage. (2) Map transition risks: carbon pricing trajectory (EU ETS), low-carbon materials cost premium, client requirements. (3) Estimate financial exposure ranges. Start with a 1-page risk register.
4. ESRS 2 SBM-2: Map your key stakeholder groups (clients, employees, subcontractors, financiers, local communities). Document how you currently engage with them on sustainability topics (e.g. client ESG questionnaires, employee surveys, supplier codes of conduct). This can be a 1-page stakeholder map with engagement method and frequency.
5. ESRS S1-6 / S1-7: Extract headcount data from payroll/HR system: total employees by gender, permanent vs temporary, full-time vs part-time. For subcontractor workers (non-employee), collect from project management records. This data is typically already available in HR systems — it needs to be extracted and validated for the reporting year.
6. ESRS E4: Conduct an E4 materiality screening: (1) identify all project sites near protected areas (Natura 2000, national parks), (2) assess soil sealing and land-take per project, (3) review Dutch Nature Conservation Act compliance per planning permission. Engage a biodiversity specialist for sites with potential habitat impacts. Document screening outcomes to support a materiality conclusion.
7. ESRS E5: Conduct an E5 materiality screening: (1) quantify construction and demolition waste by type from project waste manifests, (2) document recycling/reuse rates from waste processor certificates, (3) identify top-5 material inputs by mass (concrete, steel, timber, aggregates), (4) review circular economy initiatives (prefabrication, material reuse, design for disassembly). Use output to support a materiality conclusion on E5.
7. Standards & Methodology Reference
7.1 Regulatory Framework & Standards
| Standard | Description | Applicability | Link |
|---|---|---|---|
| CSRD (EU) 2022/2464 | Corporate Sustainability Reporting Directive | Legal basis for all ESRS disclosures | [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464) |
| ESRS 2 (2023/2772) | European Sustainability Reporting Standard 2 — General Disclosures | GOV, SBM, IRO cross-cutting disclosures | [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2772) |
| ESRS E1 (2023/2772) | European Sustainability Reporting Standard E1 — Climate Change | All E1-1 through E1-9 disclosures | [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2772) |
| ESRS S1 (2023/2772) | European Sustainability Reporting Standard S1 — Own Workforce | S1-1, S1-6/7, S1-14, S1-16 disclosures | [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2772) |
| EFRAG IG1 | EFRAG Implementation Guidance — Materiality Assessment | Double materiality assessment methodology | [EFRAG](https://www.efrag.org/en/projects/esrs-implementation-guidance/ig-1-materiality-assessment) |
| EFRAG IG3 (Dec 2024) | EFRAG Implementation Guidance — Datapoints Addendum | E1 datapoints completeness reference | [EFRAG](https://www.efrag.org/en/projects/esrs-implementation-guidance/ig-3-list-of-esrs-datapoints) |
7.2 Emission Factor Databases & Methodologies
| Source | Description | Used For | Link |
|---|---|---|---|
| GHG Protocol Corporate Standard | WRI/WBCSD Scope 1 & 2 accounting methodology | Scope 1, 2 calculations | [ghgprotocol.org](https://ghgprotocol.org/corporate-standard) |
| GHG Protocol Scope 3 Standard | Corporate Value Chain accounting | Scope 3 calculations | [ghgprotocol.org](https://ghgprotocol.org/standards/scope-3-standard) |
| IPCC AR6 GWP100 | Global Warming Potential factors (2021) | CO2e conversion | [IPCC AR6 WG1](https://www.ipcc.ch/report/ar6/wg1/) |
| DEFRA 2025 | UK Government GHG Conversion Factors for Company Reporting | Fuel combustion, transport emission factors | [UK Gov](https://www.gov.uk/government/collections/government-conversion-factors-for-company-reporting) |
| ICE Database v4.1 | Inventory of Carbon & Energy (Bath/Circular Ecology, 2023) | Embodied carbon factors for construction materials | [Circular Ecology](https://circularecology.com/embodied-carbon-footprint-database.html) |
| ecoinvent v3.10 | Life Cycle Inventory database | Background processes, Scope 3 factors | [ecoinvent.org](https://ecoinvent.org/) |
| ÖKOBAUDAT | German Federal Ministry (BMWSB) EPD database | Construction material EPDs (DACH region) | [oekobaudat.de](https://www.oekobaudat.de/) |
| GLEC Framework v3 | Global Logistics Emissions Council | Category 4 transport emission factors | [smartfreightcentre.org](https://www.smartfreightcentre.org/en/our-programs/global-logistics-emissions-council/) |
| JRC EU Electricity | EU Joint Research Centre grid emission factors | Scope 2 location-based (EU grid mix) | [JRC ENER](https://publications.jrc.ec.europa.eu/) |
| Climatiq | Emission factor API (aggregated databases) | Cross-validated emission factors | [climatiq.io](https://www.climatiq.io/) |
Report generated by: Sustainability Platform v1.0 (MVP)
Standards basis: ESRS E1 as adopted by Commission Delegated Regulation (EU) 2023/2772
Disclaimer: This is a draft gap analysis report for internal use and pilot demonstration. Not for external publication or regulatory submission without expert review and validation.