Electricity Consumption Data for CSRD: How ESG Teams Get Audit-Ready Data

If you are reading this, you already know CSRD. Your company is in Wave 1, preparing for the revised Wave 2, or reporting voluntarily because investors, banks, or larger value-chain customers ask for it. The ESRS E1-5 requirements are documented in the standards. The effort goes into the underlying data: measured electricity consumption data from Operations, in a form that survives external assurance.

The data exists. It sits with the energy or facility management team, in a dozen different formats from a dozen grid operators, and typically reaches your desk only a few weeks before the deadline, often incomplete. This article is for ESG teams that already understand the regulation and now need a data pipeline.

Where you stand after Omnibus I

A brief refresher. For the complete picture, see our full EEffG and CSRD overview.

Under the Omnibus I Directive (published in the EU Official Journal on February 26, 2026), the scope now looks like this:^[1]

• Wave 1: Large public-interest entities (around 120 companies in Austria), already reporting for FY 2024.
• Wave 2 (revised): More than 1,000 employees and more than €450M turnover. Reports for FY 2027, due in 2028.
• Wave 3 (removed): Listed SMEs are out of mandatory scope. Voluntary CSRD reporting remains possible.

Approximately 80% of originally in-scope companies are no longer obligated. For those still in, and for voluntary reporters, the data requirements have not been relaxed. Austria's NaBeG (Nachhaltigkeitsberichtsgesetz), in force since February 19, 2026, includes one practical concession: for the first three years, sanctions for content errors apply only if a correction request is ignored.^[2] The data quality requirements themselves remain unchanged.

A further round of ESRS simplifications (Omnibus II) has been announced for 2026 but had not yet been published in the Official Journal at the time of writing.

What ESRS E1-5 demands for electricity, precisely

ESRS E1-5 (Energy consumption and mix) is the core energy disclosure standard. The unit is MWh on a lower-heating-value basis.

Total energy consumption must be disaggregated by source type (Paragraph 37):^[3]

• Fossil sources (total)
• Nuclear sources (total)
• Renewable sources, further broken down into:
  • Fuel consumption from renewable sources
  • Purchased electricity, heat, steam, and cooling from renewable sources
  • Self-generated non-fuel renewable energy

For companies in high climate-impact sectors (NACE A-H, L), Paragraph 38 requires additional disaggregation of fossil sources, including purchased electricity from fossil sources.^[4]

Two nuances that are often missed in practice:

1. ESRS E1-5 does not require per-site disclosure. Reporting is at the entity level.
2. ESRS E1-6 (GHG emissions) does require Scope 2 calculations using both the location-based and the market-based method.^[5] In practice, you need your electricity consumption at least per grid region. Otherwise you cannot calculate accurate emissions.

The split into fossil and renewable for purchased electricity does not come from the meter. It comes from your supplier's electricity disclosure (in Austria, the Stromkennzeichnung), which in turn rests on guarantees of origin (AIB EECS). The kWh come from the grid operator. The split into fossil and renewable comes from the supplier.

What "audit-ready" actually means at limited assurance

Assurance starts at limited assurance under ISSA 5000, with a planned transition to reasonable assurance by 2028. A limited-assurance engagement does not re-test every figure. It tests whether the disclosures are plausible, consistent, and traceable.^[6]

Audit-readiness guidance from the major assurance firms consistently identifies the same inputs for the energy section:

• Metering data extracts: time-stamped readings at the source, not pre-aggregated spreadsheets
• Calculation files showing how kWh rolled up to MWh and into the ESRS E1-5 breakdown
• Sources for conversion factors: supplier electricity disclosure, guarantees of origin, emission factors
• Reconciliation: measured kWh reconciles to billed kWh on the same metering points

The thread running through all of it: measured, not estimated, with end-to-end data lineage from the meter to the reported MWh.^[7] A PDF list emailed quarterly by a facility manager does not clear this bar. An XLSX export from a supplier portal helps only partially; it typically lacks lineage at the metering-point level. KPMG flagged this directly in its first-year CSRD findings: companies that built documentation in from the start had far less rework later.

The organisational problem ESG teams know well

Meters live with Operations. The report lives with ESG, reporting to the CFO. Between the two are several departments and a handful of spreadsheets.

The default pattern looks like this:

1. The ESG team asks Operations for "the energy data for CSRD".
2. The energy or facility team starts collecting: logging into ten grid operator portals, manual downloads, consolidating across sites and consolidated entities.
3. Shortly before the deadline, an Excel file arrives. It is incomplete: some portals had access issues, several sites are missing readings.
4. The ESG team reformats, checks, follows up. The auditor finds gaps.
5. Next year, the same process starts from scratch.

A company with 40 sites can touch ten or more grid operators — each with its own portal, format, and response time. Manually, that is a project every year; a better Excel template will not fix it. What helps is giving the ESG team direct access to the same measured data Operations sees.

What changes with an automated electricity data pipeline

When electricity consumption data flows automatically from the grid operator, in one format, across all sites, the logic of report production shifts:

• Annual MWh = sum of the meter's own measured values, with no calendar-year extrapolation from billing cycles and no estimated periods filled in from load profiles.
• Data lineage is built in: every MWh decomposes into a list of metering points; every metering point decomposes into a grid operator record. The audit trail is part of the data, not a separate exercise.
• Reconciliation with the books gets easier: measured kWh and billed kWh both ultimately come from the same grid operator records. Discrepancies become explainable (billing cycles, estimated values for periods not yet finalized).
• Multi-year continuity: the FY 2024 baseline is already in place when Wave 2 obligations bite for FY 2027.
• Cross-site comparability: data from Vienna (Wiener Netze), Lower Austria (Netz NÖ), and Styria (Energienetze Steiermark) arrives in the same format, with no per-grid-region translation step.

Smart meters record consumption in 15-minute intervals, but for the CSRD report itself the relevant numbers are annual MWh totals. The same data can be reused by Operations for analysis, for example to identify load patterns and savings opportunities.

Where electricity stops in CSRD

An honest boundary belongs in any ESG report, and in any article about CSRD data. Smart meter electricity data gives you one row in ESRS E1-5: the kWh (converted to MWh) per reporting period, with data lineage per metering point.

What does not come from meter data:

• The fossil/nuclear/renewable split for purchased electricity. That comes from your supplier's electricity disclosure (Stromkennzeichnung) and where applicable from guarantees of origin (AIB EECS).
• CO₂ emission factors for ESRS E1-6 Scope 2. Those come from AIB data, national grid mix factors, and contractual supplier information.
• Other energy carriers (gas, district heating, transport fuel): separate data sources.
• Scope 1 and Scope 3 emissions: separate data models.

The electricity piece is one building block. Companies that automate it reliably reclaim weeks of manual data work per reporting cycle — time that goes into Scope 1, Scope 3, and the qualitative disclosures, where it is actually needed.

Checklist: Electricity data for the next CSRD cycle

1. Confirm scope. Wave 1, Wave 2 mandatory (>1,000 employees and >€450M turnover), or voluntary. Check group-level consolidation.
2. Inventory metering points. One row per Zählpunktnummer (the 33-character meter ID), per site, per consolidated entity.
3. Define ownership. Operations holds the meter-holder relationship and manages consents; ESG consumes the data directly from the same source.
4. Establish automated delivery. Daily flow, not a quarterly Excel handoff. With multiple grid operators, a single unified format is the only practical option.
5. Structure the assurance file. Raw extracts + roll-up calculation + supplier electricity-mix evidence + reconciliation with electricity invoices. Set this structure up once; populate it every year.
6. Plan back from the filing date. Who needs what, by when. Each new metering point requires a consent step by the meter holder; plan this in early.

How energiedaten.at delivers the electricity piece

energiedaten.at provides exactly that one row: measured electricity consumption data from Austrian smart meters, daily, in one unified format across all 140+ grid operators, via API, webhook, or CSV.

Each kWh is traceable to a metering point and to the grid operator record it came from. The data extract for the auditor is an API export. The full pipeline from smart meter to your system (request, consent, delivery, quality monitoring) is what we handle; you see the data.

We deliver the electricity building block. The CO₂ conversion, your supplier's electricity disclosure, the data for gas and district heating, the report itself — those stay with you or your reporting tool.

From €29/month with a 14-day free trial.

[1] Omnibus I Directive (EU), published in the Official Journal on 26 February 2026: revised mandatory thresholds for Wave 2 (>1,000 employees and >€450M turnover) and removal of Wave 3.

[2] Nachhaltigkeitsberichtsgesetz (NaBeG), BGBl. I, in force since 19 February 2026: Austria's national transposition of the CSRD, including a three-year grace period for content errors.

[3] Commission Delegated Regulation (EU) 2023/2772, Annex I (ESRS E1), Paragraph 37: disaggregation of energy consumption by source type.

[4] Commission Delegated Regulation (EU) 2023/2772, Annex I (ESRS E1), Paragraph 38: additional disaggregation of fossil sources for high climate-impact sectors (NACE A-H, L).

[5] Commission Delegated Regulation (EU) 2023/2772, Annex I (ESRS E1), Disclosure Requirement E1-6: Scope 2 emissions under the location-based and market-based methods.

[6] KPMG, "CSRD First Year Learnings" (2025): limited assurance under ISSA 5000 tests whether disclosures are plausible, consistent, and traceable; preparers with high-quality documentation, clear ownership, and verifiable data in place from the start reported fewer rework cycles.

[7] EY, "Building trust and powering reliable reporting: end-to-end data lineage" (May 2025): every reported data point should be traceable to original source documentation, with documented origin, business logic, aggregation, and controls.