What CSRD Requires Today

CSRD and the ESRS standards don’t mention IT infrastructure as a separate topic.

• Energy use: clearly in scope, reported under ESRS E1 (climate).

• Embedded emissions: hidden in scope 3.1 (“purchased goods and services”), but rarely broken down into IT.

That means most companies will stay compliant by reporting energy use, while skipping a huge share of their actual IT impact.

The Blind Spot: Embedded Emissions in IT

Why does this happen?

• Energy is easy to meter and audit.

• Embedded emissions require complex supply chain data and lifecycle assessments.

• Regulations have been designed to keep reporting manageable.

The result: companies miss out on half (or more) of the footprint of their servers, and nearly all of the footprint of their laptops.

And there’s more: if you don’t see embedded emissions, you also don’t see the potential of making IT more circular. Extending hardware lifecycles, buying second-life equipment or reducing e-waste directly cuts emissions and costs, but it doesn’t show up in today’s reporting frameworks.

Why This Matters for Compliance and Strategy

Today, companies only need to be compliant. Tomorrow, expectations will rise.

• Sector-specific standards will push for more detail.

• Assurance teams will ask harder questions.

• Stakeholders will demand proof that companies look beyond “tick-the-box” energy reporting.

Companies that already include IT’s hidden footprint will be future-proof. They’ll also be able to show cost savings and reduced risks alongside compliance.

Circular IT as the Missing Link

This is where circular IT comes in. By making IT infrastructure more circular, companies can:

• Save costs by extending hardware lifecycles.

• Reduce CO₂ emissions hidden in production.

• Cut e-waste and strengthen sustainability reporting.

At SAVE DCS, we help companies bring IT into their CSRD reporting: first making impacts visible, then building a roadmap, applying circular solutions and finally translating results into assurance-ready reporting.

How to Act Now

• Start with what’s required: energy and scope 2.

• Add insights into IT hardware footprints to prepare for the next wave of CSRD.

• Use circular IT not just for compliance, but to combine cost reduction and sustainability in one strategy.

Key Takeaways

• CSRD today = mainly energy use of IT.

• Embedded emissions = 50–90% of the real footprint, but overlooked.

• Circular IT = chance to save costs, reduce CO₂ and get ahead of future reporting.

👉 Curious where your IT stands? Request a free CSRD IT Lifecycle Quickscan and see how you can save costs, cut CO₂ and strengthen your CSRD reporting.