Mid-year is often the time when many organisations have only just begun to catch their breath after the annual reporting and sustainability reporting season. For many companies, the annual report and sustainability report were only recently finalised, submitted, and published during the first quarter.
But for teams responsible for ESG data or Sustainability Report development, the important question is this: should we wait until year-end before starting to collect ESG data again?
The answer is no.
ESG reporting today is no longer simply about compiling sustainability-related activities and presenting them in a complete report. It is increasingly moving toward disclosure that is more closely connected to business strategy, risk management, operational performance, and financial information, especially under the direction of the IFRS Sustainability Disclosure Standards, which comprise IFRS S1 and IFRS S2 developed by the International Sustainability Standards Board, or ISSB.
IFRS S1 requires organisations to disclose information about sustainability-related risks and opportunities that could affect the entity’s cash flows, access to finance, or cost of capital over the short, medium, and long term. Meanwhile, IFRS S2 focuses on climate-related disclosures, covering governance, strategy, risk management, as well as metrics and targets.
In Thailand, the Securities and Exchange Commission has communicated its direction to enhance sustainability-related disclosures by issuers and listed companies in alignment with the ISSB Standards. In the initial phase, the focus will be placed on climate-related information, or climate-first reporting, together with the disclosure of greenhouse gas emissions covering Scope 1 and Scope 2, as well as a more standardised and credible assurance process.
This is why the second half of the year is not too early to start preparing ESG data. In fact, it is the right time to put the data system in place before the reporting season returns.
Many organisations are familiar with the same recurring situation when the reporting period begins. ESG data may still be incomplete. Data sources may not be clearly identified. Supporting evidence may not align with the disclosed figures. Data from subsidiaries, suppliers, and internal departments may also arrive in different formats, requiring significant time to organise, validate, and reconcile.
These issues may once have been seen as a normal part of the reporting process. However, under increasingly rigorous disclosure standards, “good enough” data may no longer be enough.
Today, a credible ESG report needs to be able to answer several key questions. Where does the data come from? Who owns the data? How was it calculated? Is there supporting evidence? How does it connect to the organisation’s risks and opportunities? And can the data be traced and reviewed retrospectively?
The first step is to review the ESG data required for this year’s report. This should include data disclosed in previous years, data required by the reporting standards currently used by the organisation, and any new information that may need to be prepared in response to the direction of ISSB, IFRS S1, and IFRS S2.
Organisations should then clearly identify the owner of each data point. This helps clarify which department is responsible for environmental, social, governance, human resources, supply chain, risk, finance, and operational data, and who is accountable for collecting, reviewing, and confirming that data.
An ESG data collection plan or data calendar should also be developed for each relevant department. This should define the reporting timeline, data format, collection method, and required supporting evidence from the beginning of the process. Doing so can help reduce inconsistencies in data formats and prevent the Sustainability team from spending the end of the year correcting data point by point.
Another area that should begin immediately is the review of supporting evidence for ESG disclosures, particularly for key quantitative indicators such as energy consumption, water use, waste, occupational accidents, employee training, grievances, human rights, supplier assessments, and greenhouse gas emissions.
For climate-related data, organisations should prepare Scope 1 and Scope 2 information with greater readiness, including organisational boundaries, calculation methodologies, emission factors, supporting documents, and assurance processes. At the same time, organisations should begin developing a system for Scope 3 data, which relates to the value chain and supplier information, as this type of data requires time to request, collect, verify, and align across relevant parties.
Finally, internal review should take place before year-end, not only when the report is close to completion. This process should involve Sustainability, Finance, Risk, Operations, Procurement, Human Resources, Investor Relations, and senior management. ESG data should not be treated merely as information for reporting, but as information that reflects how the organisation is being managed in practice.
The key to ESG reporting in this new era is shifting from “report production” to the development of an organisational data system.
Sustainability-related information involves many functions, from corporate strategy, risk management, costs, procurement, resource use, employee management, supplier management, and corporate governance to potential financial implications in the future.
The IFRS Sustainability Disclosure Standards emphasise information that is useful to investors and users of general purpose financial reports. The focus is on disclosures that help users understand how sustainability-related risks and opportunities may affect the prospects of the organisation. Therefore, organisations that want to strengthen their ESG reporting should begin by strengthening their internal data system, rather than waiting until the reporting period to start collecting information.
As ESG standards become more rigorous, a good report is not necessarily the one with the most beautiful design or the highest number of pages. It is the report that is supported by reliable data, clearly traceable sources, reviewable evidence, and a genuine reflection of how the organisation is systematically driving sustainability.
When organisations start preparing data in the second half of the year, the outcome is not only a report that can be completed on time. It is also a more structured working process, stronger collaboration across departments, and ESG data that is ready for reporting, assessment, and long-term strategic decision-making.
If you are unsure how ready your organisation is for ESG reporting this year, you can start by checking your ESG readiness here:
https://preconsultancybkk.com/en/self-assessment/
Because good ESG reporting should not begin when everything becomes urgent. It should begin while the organisation still has enough time to build a data system that is accurate, complete, and credible.
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