CSRD Is Not an ESG Exercise – It’s a Site Data Problem (And 2026 Is the Year It Bites)
By 2026, sustainability and compliance teams across construction and infrastructure are confronting a difficult reality: CSRD compliance is being won or lost on site.
The Corporate Sustainability Reporting Directive has moved ESG reporting from voluntary narrative to regulated disclosure. Under ESRS E5, companies must report on resource use, waste generation, and circularity using reliable, verifiable data. This includes subcontracted activity — particularly material transport and disposal — which sits firmly within Scope 3.
For many contractors, this is where risk concentrates. Construction projects depend on third‑party hauliers and waste operators, yet accountability for reporting does not transfer with the truck. Regulators and auditors are increasingly explicit: if the activity happens on your project, it is your responsibility to report it accurately.
Across the EU, environmental enforcement is tightening. Authorities are scrutinising waste classification, recovery claims, and destination compliance. In Ireland, construction waste documentation is a growing focus. In the UK, Digital Waste Tracking is moving from pilot phases to enforceable expectation.
The weakness exposed again and again is data fragmentation. Sustainability teams are asked to stand over disclosures built from spreadsheets, PDFs, scanned dockets, and supplier declarations collected months after the fact. In 2026, this is no longer considered audit‑grade.
The organisations coping best with CSRD are changing how data is generated. Instead of treating ESG as a reporting exercise, they are embedding control at source. One standard movement record — time‑stamped, geo‑referenced, linked to material codes and authorised facilities — feeds compliance, ESG, and operational reporting simultaneously.
This reduces risk, but it also creates value. High‑quality movement data allows sustainability teams to analyse waste intensity, reuse opportunities, and emissions performance with credibility. It supports transition planning, not just disclosure.
CSRD is now a board‑level issue. And that means site data is no longer a sustainability problem. It is an operational one.