The hardest part of EINF reporting is not understanding the requirements, it is finding the data. Organisations often discover that the information exists but is spread across dozens of departments, systems and file formats. This guide explains where to look for each of the five pillars, who usually owns each data point, what evidence to keep and how the independent verifier will look at it.
Before you start: build a data inventory
Start with a simple inventory: one row per data point, with columns for the pillar, the unit, the source system or document, the owner, the deadline and the evidence you will keep. It takes a few hours, and it saves weeks later because it exposes the gaps (a site with no meter readings, a country with a different HR system) before the drafting deadline.
Two rules make the inventory work:
- Match the reporting boundary. Every entity in your EINF scope must appear for every relevant data point. If a subsidiary is in scope, its energy, headcount and policies are too.
- Fix definitions upfront. Decide what counts as an employee (headcount or full-time equivalent, at year end or as an average), which units you use and which emission factors apply. Then send those definitions to every owner.
Environmental data sources
| Data point | Typical source | Usual owner |
|---|---|---|
| Energy consumption | Utility invoices, ERP energy module, meter readings | Operations, Facilities |
| GHG emissions | Calculation from activity data and emission factors | Sustainability team |
| Water consumption | Water utility bills, meter readings | Facilities |
| Waste generation | Waste management contractor reports | Operations |
| Raw materials | Procurement records, supplier declarations | Procurement |
For emissions calculations, use up-to-date emission factors from recognised sources such as DEFRA or the GHG Protocol, and record which factor and which year you applied to each activity. Outdated or undocumented factors are one of the most common audit findings. Keep the invoices and reports themselves, not only the totals: the verifier will sample individual figures and ask to see the document behind them. For more on this pillar, see our guide to EINF environmental reporting.
Social and employee data sources
Most social data lives in your HRIS or payroll system: headcount by gender, age and country, contract types, new hires and turnover, absenteeism, training hours and remuneration by gender and professional category. Health and safety data (accident frequency and severity, work-related illness) usually comes from the health and safety team or the occupational risk prevention service. Work organisation data, such as working hours, flexible work arrangements and disconnection policies, may require HR policy documents rather than system exports.
If your company operates across several countries, make sure local HR teams report with the same definitions and the same cut-off date. A headcount at year end in one country and an annual average in another produces totals that do not add up, and the verifier will notice.
Human rights and anti-corruption
These pillars are mostly qualitative disclosures based on corporate policies, compliance programmes and internal audit reports. Ask your legal and compliance departments for:
- The code of conduct and the anti-corruption and anti-bribery policies, with their approval dates.
- Due diligence procedures, including how human rights risks are assessed in the supply chain.
- Whistleblowing channel records: complaints received, investigated and resolved.
- Training records on ethics and compliance.
- Confirmed incidents, legal proceedings or sanctions, if any.
Even if your company has had no incidents, you must describe the policies and mechanisms you have in place, and say so explicitly. “No cases reported” is a valid disclosure only when it is backed by records from the channel.
Diversity data
Board composition data (gender, age range, professional background, nationality) comes from the board secretary. Pay gap analysis requires payroll data segmented by gender and job category, which HR and payroll have to prepare together. Companies subject to both the EINF and the CSRD should align their diversity data collection now, as the CSRD asks for more granular breakdowns.
How the verifier looks at your data
The independent verifier checks completeness, accuracy and consistency. In practice, that means they will:
- Pick a sample of figures and ask for the source document behind each one.
- Recalculate derived metrics, such as emissions from energy consumption.
- Check that totals agree across the report and with the financial statements.
- Compare with the previous year and ask about large changes.
If every figure in your inventory already points to its source file and calculation, these requests take minutes rather than days.
Common pitfalls
- Data scattered across departments: no single team owns all EINF data, and nobody consolidates it until the deadline.
- Inconsistent units: energy in kWh at one site and MWh at another, waste in tonnes and kilograms.
- Missing historical data: year-over-year comparisons need at least two years of data on the same basis.
- No evidence trail: auditors need to trace every number back to a source document.
- Spreadsheets overwritten every year: the version you reported last year is gone when the verifier asks about it.
Data collection checklist
- Data inventory with pillar, unit, source, owner, deadline and evidence for each data point
- Definitions and emission factors agreed and shared with every owner
- Every entity in the reporting boundary covered
- Source documents stored next to the figures they support
- Previous year’s figures available on the same basis
- Anomalies reviewed and explained before drafting
How Dcycle helps
Dcycle acts as a central hub for all EINF data. Connect your ERP, upload invoices or import spreadsheets, and assign data collection tasks to each department, so everything flows into a single platform with automatic unit conversion and evidence linking. Our automated data collection reads and classifies documents, and flags exceptions such as missing months, duplicates or values that move away from the historical trend. In EINF/GRI projects, every figure keeps its linked files, so the evidence pack is ready when the verifier asks. Request a demo to see how it works.
Frequently asked questions (FAQs)
Who should coordinate EINF data collection?
One coordinator, usually in sustainability or finance, should own the data inventory and the deadlines, while each department remains responsible for its own data points and evidence.
What evidence does the EINF verifier ask for?
The verifier samples reported figures and asks for the documents behind them: invoices, meter readings, HR exports, contractor reports, policies and records. They also check the calculation methods and emission factors used.
Do I need data from previous years?
Year-over-year comparisons are expected wherever data allows. If this is your first EINF, state it clearly and collect the data on a consistent basis so you can compare from the second year onwards.
What if we have no incidents to report on human rights or corruption?
You still need to describe the policies, due diligence procedures and complaints channels you have in place, and state that no cases were reported, backed by the channel's records.
