CSRD for Banks and Insurers: Who to Hire and What to Ask
Banks and insurers report differently: financed emissions, Taxonomy ratios, Pillar 3. What sector-fit CSRD help looks like and what to ask before hiring.
João Aguiam
· 5 min read
A bank's CSRD report is not a corporate report with different numbers. The risk is hiring an adviser who has done twenty manufacturing reports and none for a lender, and finding out at the first financed-emissions question.
This guide is for the sustainability or finance lead at a bank, insurer or asset manager. It covers what changes for your sector, which skills to test for, and what to ask. For the sector overview, see our industry sector guide.
Why a Bank's Report Is Not a Corporate Report With Different Numbers
For most companies, the large numbers sit in their own operations and supply chain. For a financial institution, the large numbers sit in the portfolio: loans, investments and underwritten risks. Your own offices are small by comparison.
That changes the work in three ways:
- Your data comes from your clients. Borrowers and investees supply the inputs, and many do not yet report themselves.
- Estimates are unavoidable. You will use proxies where data is missing, and you need an adviser who can document them.
- You already report something. Taxonomy ratios and prudential disclosures exist, and the CSRD report has to sit consistently beside them.
What Changed for Financial Institutions After the Omnibus
Two things matter. Our Omnibus guide has the full picture.
The scope test is narrower. Mandatory reporting now needs more than 1,000 employees and more than 450 million euro net turnover, both exceeded. For banks and insurers, how "net turnover" is calculated differs from the corporate definition in the Accounting Directive. Do not assume the corporate reading. Check the definition for your type of institution, or get a legal view, before you decide you are in or out.
There are no sector standards. The Omnibus removed the planned sector-specific ESRS (Art. 2(6)(a)); it did not postpone them. The Commission may publish non-binding sector guidance. In practice, the sector knowledge no longer lives in the standard. It lives in the adviser. That is why this choice matters more than it did.
The Sector Skills to Test For
Four areas separate a sector-fit adviser from a general one.
- Financed emissions. Measuring Scope 3, category 15 across lending, investments or underwriting, choosing methods by asset class and handling poor data. Our Scope 3 guide covers the categories; ask the adviser how they apply it to a loan book.
- Taxonomy ratios. The Green Asset Ratio for credit institutions, and the investment, underwriting and fees KPIs for other institutions. See the EU Taxonomy guide for what each requires. Ask which ratio they have produced for a client like you.
- Pillar 3 ESG. Banks already publish ESG risk disclosures under prudential rules. The adviser should know where those and the CSRD report must agree, without advising on prudential supervision itself.
- SFDR links. If you manage funds or sell products, the same portfolio data feeds SFDR disclosures. A good adviser maps one data set to both.
Specialist or Generalist: When Each Is Enough
A generalist is enough when the exercise is the process around the numbers: running the double materiality assessment, setting up governance, drafting narrative, preparing for assurance. These are the same for every sector.
You need a specialist for the portfolio calculations and the consistency with Taxonomy, Pillar 3 and SFDR data. Many institutions pair the two: a general lead for the programme and a sector specialist for the financial-sector modules.
The trap is hiring a generalist who says the sector part is "just Scope 3". It is the part where the numbers are largest and the data is worst.
Questions to Ask
These five go beyond the general list in our questions to ask a CSRD consultant.
- Which financed-emissions method would you use for each of our asset classes, and how do you treat missing data?
- Which Taxonomy ratio have you produced for an institution like ours, and who on your team did it?
- How would you keep the CSRD report consistent with our Pillar 3 and SFDR disclosures?
- How will you collect data from borrowers and investees who do not report?
- Who from your team will work on our engagement, and what have they done in a bank or insurer?
If answers come back about "the firm" and not about named people, treat it as a no.
Assurance: Limited Only
The sustainability statement is subject to limited assurance. The step-up to reasonable assurance was dropped, and the Commission is adopting limited-assurance standards by 1 July 2027. Who may provide the assurance depends on how your member state transposes the Directive, which is due by 19 March 2027. Our assurance guide explains what the engagement involves.
Two practical points. Your adviser should not be your assurance provider for the same cycle. And financed-emissions estimates are where an assurer will want documentation, so ask your adviser what evidence file they produce for them.
Where to Find One
Our directory lists advisers with EU Taxonomy, SFDR, ESG KPI and ESG data experience, and the Financial Services page collects guides and experts for the sector. Check each profile for actual work in banking, insurance or asset management, and ask for a reference from a similar institution.
Are you a CSRD consultant? Get listed.
