publication

What CSRD Auditors Look For in Your External Climate Actions

May 4, 2026

Table of contents

Carbon offsetting, contribution, insetting: under ESRS E1, every external climate investment is now subject to formal audit. Most sustainability teams discover the gap between what they declared and what they can actually prove during the audit, not before.

We mapped what auditors systematically look for, in the order they ask, and the documentation traps that turn a routine review into a greenwashing flag. 11 pages, built from real CSRD audit observations.

Why CSRD turned climate reporting into a forensic exercise

Until 2024, climate investments lived in voluntary reports. Nobody verified the claims.

Since ESRS came into force, an external auditor examines the evidence. Carbon credits must be reported separately under ESRS E1-7, with no netting against gross emissions. The CRCF regulation (in force 2026) introduces strict criteria on additionality and reversal risk. The Green Claims Directive restricts public claims like "carbon neutral" or "net zero".

Three regulations. One audit. A new profession sitting between you and your sustainability report: the auditor.

What happens when the evidence is missing

A growing list of companies acted in good faith and could not document what they had said publicly:

  • KLM (2024): Dutch court ruled the airline misled consumers with "Fly Responsibly" claims. Offsets were not sufficient evidence.
  • Apple "carbon neutral" Watch (2024): European consumer organisations filed complaints arguing the claim could not be substantiated.
  • DWS / Deutsche Bank (2023): 25 million dollar settlement with the SEC over ESG misstatements. Documentation gaps, not bad intent.
  • Vattenfall (2023): Swedish ASA banned "fossil-free" advertising as misleading.

What the guide gives you

Built from real audit observations, the guide is a working document, not a thought piece. It is structured around the 5 questions auditors systematically ask about external climate actions, in the exact order they come up. For each question, you get:

  • The specific documents the auditor expects on the table
  • The wording traps that turn a defensible answer into a flag
  • A side-by-side reference for the two regimes (offsetting vs contribution) that look similar but lead to opposite legal exposures
  • A pre-audit checklist to run two weeks before your statutory auditor walks in.

Why Soil Capital wrote this

Soil Capital runs Europe largest insetting programme: 1,800 farmers, 500,000 hectares, 16 million euros paid to farmers for measured carbon outcomes. Our MRV is TÜV verified and ISO 14064-2 certified. We have sat next to sustainability teams during dozens of CSRD audits. This guide is the playbook we wish every team had two weeks before their first review.

Take a step towards us

Register to the event

Download the Guide

First Name*
Last Name*
Company Name*
Email*
Phone number
Thank you!
Access to the content now :
Download nowTélécharger maintenant
Oops! Something went wrong while submitting the form.

Table of contents

Carbon offsetting, contribution, insetting: under ESRS E1, every external climate investment is now subject to formal audit. Most sustainability teams discover the gap between what they declared and what they can actually prove during the audit, not before.

We mapped what auditors systematically look for, in the order they ask, and the documentation traps that turn a routine review into a greenwashing flag. 11 pages, built from real CSRD audit observations.

Why CSRD turned climate reporting into a forensic exercise

Until 2024, climate investments lived in voluntary reports. Nobody verified the claims.

Since ESRS came into force, an external auditor examines the evidence. Carbon credits must be reported separately under ESRS E1-7, with no netting against gross emissions. The CRCF regulation (in force 2026) introduces strict criteria on additionality and reversal risk. The Green Claims Directive restricts public claims like "carbon neutral" or "net zero".

Three regulations. One audit. A new profession sitting between you and your sustainability report: the auditor.

What happens when the evidence is missing

A growing list of companies acted in good faith and could not document what they had said publicly:

  • KLM (2024): Dutch court ruled the airline misled consumers with "Fly Responsibly" claims. Offsets were not sufficient evidence.
  • Apple "carbon neutral" Watch (2024): European consumer organisations filed complaints arguing the claim could not be substantiated.
  • DWS / Deutsche Bank (2023): 25 million dollar settlement with the SEC over ESG misstatements. Documentation gaps, not bad intent.
  • Vattenfall (2023): Swedish ASA banned "fossil-free" advertising as misleading.

What the guide gives you

Built from real audit observations, the guide is a working document, not a thought piece. It is structured around the 5 questions auditors systematically ask about external climate actions, in the exact order they come up. For each question, you get:

  • The specific documents the auditor expects on the table
  • The wording traps that turn a defensible answer into a flag
  • A side-by-side reference for the two regimes (offsetting vs contribution) that look similar but lead to opposite legal exposures
  • A pre-audit checklist to run two weeks before your statutory auditor walks in.

Why Soil Capital wrote this

Soil Capital runs Europe largest insetting programme: 1,800 farmers, 500,000 hectares, 16 million euros paid to farmers for measured carbon outcomes. Our MRV is TÜV verified and ISO 14064-2 certified. We have sat next to sustainability teams during dozens of CSRD audits. This guide is the playbook we wish every team had two weeks before their first review.

Ready to future-proof your climate and regen ag strategy?
Get in touch with our team

Take a step towards us

Register to the event

Download the Guide

Thank you!
Access to the content now :
Oops! Something went wrong while submitting the form.
black cross