Purpose
Map a company's existing ESG disclosures, data, and governance practices against the specific requirements of the sustainability regulations that apply to it — then produce a prioritized gap analysis and a phased remediation roadmap that tells the CSO, GC, and Head of Compliance exactly what is missing, how serious each gap is, and what to fix first before the filing deadline.
When to Use
Invoke this skill when the user asks to:
- Assess readiness for CSRD, SEC climate rules, EU Taxonomy, TCFD, or ISSB/IFRS S1–S2 reporting
- Prepare for a first-time mandatory sustainability disclosure filing
- Diagnose where current ESG reporting falls short of a specific regulation's requirements
- Build a remediation plan to close compliance gaps before a reporting deadline
- Determine which sustainability regulations apply given the company's geography, revenue, and structure
- Prioritize limited compliance resources across multiple overlapping disclosure regimes
Inputs Required
Before starting, collect:
- Applicable or candidate regulations: Which regimes to analyze against (CSRD, SEC climate, EU Taxonomy, TCFD, ISSB/IFRS S1–S2, California SB 253/261, etc.)
- Company profile: Headquarters, jurisdictions of operation, annual revenue, employee count, listing status, and EU/US market presence — used to confirm which regulations legally apply
- Industry/sector: Sector determines material topics and sector-specific standards
- Current ESG disclosures: What is published today (annual report, sustainability report, CDP, GRI index, prior TCFD statement) and where
- Data and systems maturity: What ESG data is currently collected, how (manual vs. system), and whether Scope 1/2/3 emissions are measured
- Governance structure: Who owns ESG, board oversight arrangements, and whether assurance/audit is in place
- Reporting deadline: First mandatory filing date or target internal deadline
If applicability is uncertain, first run a scoping determination against thresholds and state the conclusion before proceeding.
Instructions
Step 1: Confirm Regulatory Applicability and Scope
Before analyzing gaps, confirm which regulations legally bind this company.
- CSRD: Applies to large EU companies and non-EU companies with significant EU turnover (€150M+ EU revenue) and an EU branch/subsidiary; determine wave/phase-in year and whether limited assurance is required
- SEC climate rules / California SB 253 & SB 261: Determine based on US listing status, revenue thresholds ($1B for SB 253, $500M for SB 261), and doing-business-in-California status
- EU Taxonomy: Applies to entities in CSRD scope; requires eligibility and alignment reporting for turnover, CapEx, and OpEx
- TCFD / ISSB (IFRS S1–S2): Determine mandatory vs. voluntary status by jurisdiction (UK, Japan, others mandating ISSB adoption)
Output a short applicability table: Regulation | Applies? (Yes/No/Conditional) | First reporting year | Assurance requirement.
Step 2: Build the Requirement Inventory
For each applicable regulation, enumerate the concrete disclosure requirements grouped by pillar:
- Governance: Board oversight, management role, ESG accountability structures
- Strategy: Material impacts/risks/opportunities, scenario analysis, transition plan, resilience
- Risk management: Identification, assessment, and integration of climate/ESG risks
- Metrics & targets: Scope 1/2/3 emissions, targets, KPIs, Taxonomy KPIs, sector metrics
- Double materiality (CSRD-specific): Impact materiality and financial materiality assessment
For CSRD, map to the relevant ESRS datapoints (E1–E5, S1–S4, G1). Note which requirements are phase-in (e.g., Scope 3, value chain data) vs. immediately required.
Step 3: Assess Current State Against Each Requirement
For every requirement in the inventory, classify current status:
- Compliant: Requirement fully met with disclosure-quality data
- Partial: Some data or disclosure exists but incomplete, unassured, or below the required standard
- Missing: No data, process, or disclosure exists
- Not applicable: Requirement excluded via a defensible materiality determination (state the rationale)
Cite the evidence for each rating from the company's current disclosures where provided.
Step 4: Rate Gap Severity and Compliance Risk
For each Partial or Missing gap, assign a severity rating:
- Critical: Non-negotiable mandatory disclosure with no data foundation and hard deadline exposure — creates filing failure or legal liability
- High: Mandatory requirement partially met but insufficient for assurance or audit sign-off
- Medium: Required but phased-in, or achievable with existing data reorganization
- Low: Voluntary, best-practice, or low-effort completion
Factor in three dimensions: legal exposure (mandatory vs. voluntary), data build time (how long remediation realistically takes), and assurance risk (whether an auditor would flag it).
Step 5: Rank Compliance Priorities
Produce a ranked priority list combining severity, deadline proximity, and remediation lead time. Long-lead-time items (Scope 3 data collection, double materiality assessment, assurance readiness) rank higher even at equal severity because they cannot be completed at the last minute.
Step 6: Build the Phased Remediation Roadmap
Organize remediation into three horizons:
- Phase 1 — Foundation (0–3 months): Governance, materiality assessment, data architecture, gap ownership assignment
- Phase 2 — Data & Disclosure Build (3–9 months): Emissions inventory completion, KPI collection, transition plan drafting, Taxonomy calculations
- Phase 3 — Assurance & Filing Readiness (9–12 months): Internal controls, assurance dry-run, disclosure drafting, board sign-off
For each remediation action specify: the action, the gap it closes, a suggested owner (function), estimated effort, and dependencies.
Output Format
- Structure: Structured compliance document with tables for applicability, requirement inventory, and gap ratings; ranked priority list; phased roadmap
- Length: 1,400–2,000 words
- Format: Structured document — applicability and gap sections as tables, remediation as phased action lists
- Sections: Applicability determination → Requirement inventory by regulation → Current-state gap assessment → Gap severity & compliance risk ratings → Ranked compliance priorities → Phased remediation roadmap → Key risks & assurance notes
- Tone: Compliance advisory — precise, regulation-grounded, risk-aware, and directive; written for a legal and executive audience that must act on it
Quality Checklist
Before delivering output, verify:
- [ ] Applicability is explicitly confirmed for each regulation against stated thresholds — not assumed
- [ ] Every requirement is classified as Compliant / Partial / Missing / Not applicable with evidence or rationale
- [ ] Every Partial and Missing gap has a severity rating (Critical/High/Medium/Low) with reasoning across legal, data, and assurance dimensions
- [ ] Priority ranking accounts for remediation lead time — long-lead items rank above equal-severity quick fixes
- [ ] The remediation roadmap is split into three dated phases with owners and dependencies for each action
- [ ] CSRD gaps reference relevant ESRS pillars/datapoints where CSRD is in scope
Notes
- The single most common fatal gap is Scope 3 emissions and value-chain data — it has the longest lead time and cannot be assembled near a deadline, so it should nearly always rank Critical or High
- Double materiality assessment is a CSRD prerequisite that determines which topics must be reported at all; if it hasn't been done, it belongs in Phase 1 before any data build
- This analysis supports but does not replace formal legal counsel on applicability determinations — flag where a qualified legal review is required
- Where a company faces overlapping regimes (e.g., CSRD and SEC climate), note shared data foundations so one remediation effort satisfies multiple requirements
How to use this skill
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