---
name: regulatory-sustainability-compliance-gap-analyzer
description: "Maps a company's current ESG disclosures and practices against applicable sustainability regulations (CSRD, SEC climate rules, EU Taxonomy, TCFD, ISSB, and others), then delivers a structured gap analysis with materiality-scoped requirements, gap severity ratings, compliance priority rankings, and a phased remediation roadmap with owners and deadlines. Use when assessing readiness for a sustainability disclosure regime, preparing for a first-time CSRD or SEC climate filing, diagnosing where current ESG reporting falls short of legal obligations, or building a remediation plan to close compliance gaps before a reporting deadline."
argument-hint: "[regulations] [company-profile]"
allowed-tools: ["Read"]
---

# Regulatory Sustainability Compliance Gap Analyzer

## 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

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## How to use this skill

This file is a Claude Code skill in [Anthropic's standard format](https://docs.anthropic.com/en/docs/claude-code/skills) — markdown with YAML frontmatter at the top.

**Installing in Claude Code:**
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Restart Claude Code or open a new session to register.

**Using in Claude.ai, ChatGPT, Gemini, or other AI tools:**

1. Drag this file into a new chat, or copy and paste its contents
2. Send your task or request as your next message — the AI will apply the skill where it fits

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