ESG Gap Analysis Report — Heembouw B.V. (Partial Data)

Framework: CSRD / ESRS E1 (Climate Change)

Company: Heembouw B.V. (Partial Data) (Heembouw B.V.)

Country: NL | NACE: 41.20

Employees: 200 FTE | Revenue: €38.0M

Reporting Year: FY2024

Report ID: gap_heembouw_pilot_002_1773839231233

Generated: 18 March 2026

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This gap analysis is prepared against ESRS E1 (Climate Change) disclosure requirements under the EU Corporate Sustainability Reporting Directive (CSRD). It is based on the company profile provided and does not constitute legal advice. Engage a qualified sustainability consultant for full CSRD readiness assessment.

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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.

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2. Compliance Readiness Summary

Status	Count
✅ Met	4
⚠️ Partial	1
❌ Missing	7
➖ Not Applicable	2
Total disclosures assessed	14

🔴 1 critical gap require immediate attention before any CSRD filing.

🟠 4 high-priority gaps should be addressed within the next reporting cycle.

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2a. Scope 1 / 2 / 3 Emissions — FY2024

Based on partial data. Scope 3 reflects Category 1 (purchased materials) only — Category 4 data pending.

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2b. Gap Priority Matrix

Each gap plotted by implementation effort (X) and business priority (Y). Use this to sequence your roadmap.

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3. ESRS E1 Gap Analysis — Full Detail

Disclosures are ordered by priority. Each item references the specific ESRS clause.

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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.

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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.

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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. 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.

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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.

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ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 3

Field	Value
Status	⚠️ Partial
Priority	🟠 High
Mandatory	Yes
ESRS Reference	ESRS E1, paragraphs 44(c), 51–56
CSRD Article	CSRD Art. 19a(2)(e)
Effort to Close	days

Assessment: Scope 3 data is partially available but missing key categories. Missing: Cat 4: Upstream transportation (materials logistics to site)

Missing data elements:

• 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 v3.0 emission factors (concrete: 0.103 kgCO₂e/kg; structural steel: 1.85 kgCO₂e/kg; timber: -0.31 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.

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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.

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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.

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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.

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ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 1

Field	Value
Status	✅ Met
Priority	🟢 Low
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 are documented for the reporting period.

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 2024 emission factors (e.g. diesel: 2.527 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.

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ESRS E1-6: Gross Scopes 1, 2, 3 and Total GHG Emissions — Scope 2 (location-based)

Field	Value
Status	✅ Met
Priority	🟢 Low
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 location-based GHG emissions are documented.

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.

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ESRS E1-5: Energy Consumption and Mix

Field	Value
Status	✅ Met
Priority	🟢 Low
Mandatory	Yes
ESRS Reference	ESRS E1, paragraphs 36–43
CSRD Article	CSRD Art. 19a(2)(e)
Effort to Close	days

Assessment: Energy consumption data is documented, covering total consumption and the fossil/renewable split.

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).

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ESRS E1-2: Policies Related to Climate Change Mitigation and Adaptation

Field	Value
Status	✅ Met
Priority	🟢 Low
Mandatory	Subject to materiality
ESRS Reference	ESRS E1, paragraphs 20–22

Effort to Close	weeks

Assessment: Climate policies are documented and cover the required scope.

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.

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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.

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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.

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4. 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.

🟠 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 E1-4: 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. 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.

3. 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.

4. ESRS E1-6: Prioritise Category 1 (purchased goods): collect a bill-of-materials for the top 5 projects by value. Apply ICE Database v3.0 emission factors (concrete: 0.103 kgCO₂e/kg; structural steel: 1.85 kgCO₂e/kg; timber: -0.31 kgCO₂e/kg). Use our Scope 3 Cat 1 calculator for a traceable inventory. Then address Cat 4 (transport) using GLEC Framework factors.

🟡 Medium Priority — Address Next Cycle

1. 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.

2. 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.

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5. Standards & Methodology Reference

Standard	Description	Applicability
CSRD (EU) 2022/2464	Corporate Sustainability Reporting Directive	Legal basis for all ESRS disclosures
ESRS E1 (2023/2772)	European Sustainability Reporting Standard E1 — Climate Change	All E1-1 through E1-9 disclosures
GHG Protocol Corporate Standard	WRI/WBCSD Scope 1 & 2 accounting methodology	Scope 1, 2 calculations
GHG Protocol Scope 3 Standard	Corporate Value Chain accounting	Scope 3 calculations
IPCC AR6 GWP100	Global Warming Potential factors (2021)	CO2e conversion
ICE Database v3.0	Inventory of Carbon & Energy (Bath University)	Embodied carbon factors for construction materials
DEFRA 2024	UK Government GHG Conversion Factors	Fuel combustion, transport emission factors
GLEC Framework v3	Global Logistics Emissions Council	Category 4 transport emission factors