Does Reporting Start with Data?

For many organizations, sustainability reporting is often postponed due to the perception that “no data means no report.” This is particularly common among small and medium-sized enterprises (SMEs) or institutions without prior reporting experience. However, sustainability reporting can also reflect intentions, plans, and progress—not just measured outcomes.

TSRS and GRI explicitly state that “narrative explanations are valid in the absence of complete data.”

Key principle: If data is not disclosed, explain why; if incomplete, share the improvement plan.

1. What Are the Alternative Types of Data?

Besides conventional metrics, the following data types can also produce meaningful insights in sustainability reporting:

Data Type	Description	Example
Narrative Data	Verbal explanation of policies, practices, and intentions	“Occupational health and safety is a priority topic in our annual training plan.”
Proxy / Estimated Data	Calculations based on industry averages or activity coefficients	“Using sector emission factors, our 2023 carbon footprint is estimated at 240 tons of CO₂.”
Survey & Observation-Based Data	Qualitative data collected via internal surveys or focus groups	“76% participation was achieved in our employee satisfaction survey.”

2. Alternatives to Calculations: Assumptive Methods

For areas such as carbon footprint or water consumption, the following estimation methods can be applied:

Activity-Based Estimation

• Assumption: 1 kWh electricity = 0.4 kg CO₂
• If the organization consumed 30,000 kWh of electricity:
  ➤ 30,000 × 0.4 = An estimated 12 tons of CO₂ emissions

Sector Average Usage

• In the textile industry, for example, producing 1 kg of fabric = 20 liters of water.
  If production is 500,000 kg:
  ➤ 500,000 × 20 = 10 million liters of estimated water consumption

Such estimates are acceptable when reported transparently, with sources cited and labeled as “representative.”

3. Narrative Reporting: Policy, Target, Status

Even without complete data, the structure below can reflect an institution’s vision and sustainability commitment:

Heading	Explanation
Policy	“In line with our zero workplace accident goal…”
Target	“We aim to increase annual training hours by 30% by 2025.”
Status / Intention	“A data monitoring system will be initiated in 2024.”

This structure supports transparency and shows a genuine intention to improve.

4. Tools and Practical Applications

• Excel Templates: Simplified tables for basic data entry
• Survey Modules: Brief surveys on employee satisfaction, energy awareness, etc.
• Observation Cards: Regular tracking of recycling practices, social activity participation, etc.
• Explanatory Footnotes: Reasons for data gaps and expected completion timelines

5. Reporting-Compliant Examples

TSRS Example:

“We currently lack a comprehensive energy monitoring infrastructure. However, in 2024, we will implement a data recording system for electricity, natural gas, and fuel consumption.”

GRI-Compliant:

“Under GRI 302, our energy consumption data is currently based only on electricity bills. Data on fuel and transport-related energy usage will be monitored starting in 2025.”

Conclusion: Lack of Data Is Not a Barrier—It’s a Starting Point

Each institution’s sustainability journey unfolds at its own pace. Collecting data requires time and resources. However, reporting is still possible—even in the early stages—as long as there is transparency, intent, and a commitment to progress.

At S4A, we make sustainability reporting accessible for organizations with limited data capacity through simplified templates, tailored guidance, and strategic alignment tools.