Read this first. This was a Final Master's Thesis: the client is simulated and there was no live mandate. The regulatory analysis, the framework, the financial appraisal and the project controls are real work. The client is not.
The problem
CSRD makes companies report sustainability from two directions: how sustainability issues affect the business, and how the business affects people and the environment. That is the Double Materiality Assessment. It decides what gets reported, what gets assured and what an auditor can challenge.
The ESRS say what a DMA must achieve and nothing about how to do one. Every company either builds its own or buys one from a Big Four firm, and neither route gives results comparable between companies. The most consequential step in the regime is the one with no agreed method.
What we designed
A standardised DMA framework for CSRD implementation in Spain, commissioned in the scenario by the Instituto de Contabilidad y Auditoría de Cuentas and the Comisión Nacional del Mercado de Valores and delivered by StratESG Consulting Group. The aim: a methodology that is clear, usable, auditable and repeatable, with a public toolkit, value chain guidance and a pilot application behind it.
The engagement ran 27 weeks on documentary and secondary source analysis of the regulatory corpus: the CSRD, Commission Delegated Regulation (EU) 2023/2772 (ESRS), the November 2025 ESRS drafts and EFRAG Implementation Guidance.
How it was run
The design was delivered against a full project management plan: scope, schedule, cost, quality, risk, communications, procurement, control and closure. It finished on schedule at an SPI of 1.00 and within budget at a CPI of 0.97, against a funded budget of €562,625.
The item I would point at is change request CR-005. EFRAG revised its implementation guidance mid-project, with a dependent deliverable in progress. The change was absorbed and the deadline held. That is what the controls are for: when a CR-005 lands you can see at once what it costs and what you have left.
Does it pay for itself?
Against that cost, the framework breaks even at 33 adopting companies over three years, a fraction of the in-scope population. Base case net present value is about +€123,615, rising to +€466,735 in the optimistic scenario, both at a 4% discount rate.
Omnibus I
While the work was underway, the Omnibus I simplification (Directive (EU) 2026/470) cut CSRD's in-scope reporting population to several hundred of the largest Spanish undertakings. A business case built on market size would have failed there.
This one turns on the benefit per adopter and survived with room to spare. For the large undertakings still in scope it remains a credible, regulator endorsed and affordable alternative to Big Four advisory.
It also removed a large part of the CSRD compliance market. Anyone calling CSRD expertise a growth area in 2026 is working from 2024. What remains is narrower, more technical and concentrated in the largest reporters, where a standardised, auditable method is worth most.
Where it went after the thesis
The deliverable was a framework and a toolkit. We went past the brief and worked the same idea through as a product.
Then I built it. Vera runs on Next.js, Supabase and Claude, takes an organisation through the assessment and produces the reporting output. Co-founded with two others and in commercial development, so the internals stay closed. The framework underneath is the one published here, and that part was always meant to be open.