Before you report on ESG, find out who owns the data

Sustainability programmes usually start at the top: a framework is selected, a set of disclosures is identified, targets are agreed, and a timeline is published. Then someone is asked to produce the first number, and the programme meets the question it should have started with — where does this figure come from, and who is answerable for it?

Energy consumption sits with facilities, or with whoever files the utility bills. Water may not be metered separately at all. Waste is with a contractor whose records were never designed to be reported from. Workforce data is in payroll, in a spreadsheet, and in an HR system that disagree at the margins. None of this is unusual, and all of it is discoverable before a target has been committed to publicly.

A number nobody owns is not a number

If a disclosure cannot be traced to a person who can explain how it was produced, it is an estimate with a decimal point.

This is the same standard finance reporting has been held to for a long time, and ESG data is now moving toward it. Where the two differ is that financial data usually arrives through a single system with a control structure already attached, while ESG data is scattered across functions that have never been asked to report externally and whose records were built for operational use.

The consequence is that the governance question cannot be deferred. A framework selected before ownership is established commits the business to disclosures it has no established means of producing.

Establish the base before the target

A target set against an unreliable baseline is unmanageable in both directions: progress cannot be demonstrated, and a later correction to the baseline looks like a restatement regardless of why it happened. The sequence that avoids this is straightforward, and its first three steps involve no commitment at all:

1. Inventory what is already measured

   Most businesses hold considerably more relevant data than they think, in utility bills, procurement records, payroll and maintenance logs. Start with what exists rather than with what a framework requests.

2. Name an owner for each source

   One person per data source, responsible for producing it on a defined rhythm and able to explain the basis. Where no owner exists, that is a finding, and it is better found now.

3. Establish how good the baseline actually is

   Some figures will be metered, some apportioned, some estimated. Recording which is which, honestly, is more valuable than making them look uniform.

4. Only then select the framework and the targets

   With a known baseline and known data quality, the choice of what to commit to becomes a decision rather than an aspiration.

The questionnaire is usually the real deadline

For most mid-market businesses in India, ESG does not arrive as a regulatory obligation first. It arrives as a customer questionnaire — a large buyer, often an exporter or a multinational's supply chain, asking a set of questions with a response date attached.

This matters for how the programme should be shaped. A questionnaire is specific, it is dated, and it has commercial consequence, which makes it a far more effective organising force than a general intention to improve. It also reveals precisely which data the business's customers actually care about, which is rarely the full set any framework would request.

Answering one well tends to produce the foundation for answering all of them: the sources are identified, the owners are named, and the evidence is filed where it can be found again.

Evidence is the part that gets skipped

A disclosure and the evidence for a disclosure are different artefacts, and the second is the one that is usually missing. Assurance requirements are extending across sustainability reporting, and the practical implication is that the supporting file has to be assembled as the data is produced rather than located afterwards.

This is not a new problem and the solution is not novel. It is the same discipline that makes a monthly close defensible, applied to a different set of numbers: a documented source, a stated basis, a named owner, and a file that a reviewer can follow without a guide.

The useful first meeting

Not a workshop on frameworks. A meeting with the people who hold the data — facilities, HR, procurement, operations — to establish what is measured today, by whom, and how. It is a deflating meeting and an extremely productive one, and it will tell you more about what the business can credibly commit to than any amount of strategy work conducted above it.