When operational data becomes ESG data
Across Europe, the shift toward sustainability reporting is transforming how companies manage information. What used to be treated as separate domains, such as operational battery data for compliance, or corporate ESG reporting for annual disclosures, is rapidly becoming a single, interconnected system.
The Digital Battery Passport (DBP), mandated under the EU Battery Regulation (EU 2023/1542), and the Corporate Sustainability Reporting Directive (CSRD) increasingly draw from the same evidence base: traceable, auditable, and lifecycle-centred data.
Inside the BASE project, this convergence has become clear. Whether the data originates from mining, cell production, integration, field use, second life, or recycling, the patterns are consistent: the information required for DBP compliance is exactly the information companies must present under CSRD and the ESRS standards. This is where technical becomes corporate, the operational becomes strategic. And the lifecycle becomes the central organising principle for sustainability governance.
Why DBP data aligns naturally with CSRD requirements
The DBP forces companies to measure what historically remained fragmented or undocumented: energy consumption, repair events, safety interventions, supply-chain provenance, water use, human rights risk exposure, material flows, and lifecycle emissions. These datasets are not only aligned with regulatory elements but are also deeply operational.
CSRD and ESRS require companies to demonstrate how sustainability is embedded into their strategy, governance, due diligence processes, and value-chain relationships. What BASE is testing and seeing across its pilots is that much of this data already exists inside the DBP structure. To clarify this relationship, the following comparison illustrates how DBP-aligned data directly supports CSRD disclosures.
DBP Mandatory Data Category | Operational Data Captured (Examples) | Corresponding CSRD/ESRS Requirement |
Raw material traceability & CAHRA sourcing | Supplier BPNs, proof of origin, due diligence checks | ESRS S2: Value-chain workers; ESRS G1: Governance & due diligence |
Energy use & carbon footprint | kWh per process step, on-site emissions | ESRS E1: Climate change (Scopes 1-3) |
Water use & consumption | Withdrawal, discharge, water stress zones | ESRS E2: Water & marine resources |
Safety & testing events | Thermal events, repair logs, failure modes | ESRS S1: Health & safety performance |
Waste & recycling data | Scrap fractions, yield rates, black mass outputs | ESRS E5: Circular economy |
Social & governance indicators (from BASE ESG Index) | Human rights policies, grievance mechanisms, taxation, and corruption controls | ESRS G1: Business conduct; ESRS S3: Affected communities |
Lifecycle performance data | Degradation patterns, SoH, second-life suitability | ESRS E5: Product circularity & extended use |
Table overview: How DBP evidence directly supports CSRD/ESRS requirements
This alignment is structural, not accidental. Both regulatory frameworks are built on the same underlying philosophy: strong sustainability performance must be traceable and data-driven across the entire value chain.
Insights from BASE Project: what real pilots revealed about data reuse
Across BASE pilots - from upstream extraction to electric vehicle batteries, second-life storage, and recycling - a pattern has become obvious: companies generate high-quality data during operations, but they rarely exploit it beyond immediate compliance needs. Yet this same data has significant strategic value.
During our work with the consortium partners (for now, anonymised for confidentiality), we observed several recurring insights:
1. Operational traceability = a lifecycle asset
Across multiple demonstrations, one consistent pattern emerged: the operational life of a battery continues to create value long after it leaves the vehicle - but only if its historical data is available.
In several technical pilots, we saw that batteries retiring from automotive use still retained between 70% - 80% of their original capacity, confirming wider industry research that these assets remain viable for stationary storage or other second-life applications. This remaining capacity makes early-life operational data far more important than most OEMs realise.
When this data is structured and accessible through a DBP-aligned format, organisations reduce forensic reconstruction work and avoid fragmented data hunts, often cutting evidence-collection time for ESG reporting by 30% - 50% when compared with traditional manual processes. In practice, this means that what was once a manufacturing by-product - a BMS log or test bench output - becomes a long-term strategic resource supporting valuation, compliance, and risk assessment.
2. ESG reporting accuracy improves significantly when tied to asset-level data
One of the clearest findings and feedback from the work of the “Environment, Social, Governance, and Economic (ESGE) Indicator” team was that ESG performance indicators will become more meaningful when grounded in actual battery-level data rather than plant-level averages. When we compared (pilot/mock) aggregated environmental metrics with asset-level tracking, the latter provided 15% - 25% higher resolution in emission, energy, and water-use calculations. This insight in the form of improved precision is especially important as EU reporting frameworks (such as ESRS E1–E5) move toward more granular intensity-based KPIs.
Linking ESG metrics to the DBP schema - where each battery carries verifiable evidence for its production and use (its provenance) - reduces uncertainties that typically force OEMs into conservative assumptions. The more complete the data trail, the more confidently OEMs can defend their disclosures, respond to stakeholder audits, and integrate sustainability insights into product development.
3. Circularity outcomes depend heavily on transparent first-life histories
In our second-life and repurposing pilots, the availability of first-life data repeatedly shaped both the speed and confidence of evaluations. Global projections with regard to EV battery repurposing indicate that reused EV batteries could supply 1,300 – 1,870 GWh of stationary storage capacity by 2038 in major markets.
Yet in practice, repurposers still face large gaps: incomplete stress patterns, missing cycle counts, and inconsistent degradation data. In cases where complete operational histories were available, repurposing workflows progressed smoothly; where histories were incomplete, screening times extended by as much as 40%, and synthetic modelling had to be introduced to approximate missing information.
This adds uncertainty to lifetime predictions and safety evaluations. The insight for OEMs is clear: the value of second life is directly proportional to the transparency of its first life.
4. Recycling efficiency increases noticeably when chemistry and origin are known
In recycling-focused segments of the test demonstrations, chemistry-level transparency - down to cathode formulation, electrolyte additives, and known sourcing origins - so far directly improved recovery yields. Broader industry analysis already estimates that recycled materials could supply 14% of lithium, 16% of nickel, 17% of manganese, and 25% of cobalt demand for the European EV market by 2030.
Yet achieving these numbers requires upstream clarity. In pilots so far, where recyclers had access to (demo) DBP-linked material composition and manufacturing identifiers, recovery yields increased by 12% - 18% compared with processes that treated incoming material as undifferentiated scrap.
This uplift is financially meaningful and strategically important, especially for OEMs: reclaimed high-purity materials can re-enter the supply chain at a value level close to primary materials, supporting both regulatory targets and OEM cost reduction efforts. DBP data is therefore not only a compliance obligation - it is a tool for improving resource efficiency and stabilising European supply chains.
How BASE is Making the DBP Strategic and Scalable
This convergence simply reflects a structural transition in European sustainability governance: operational data is becoming the foundation of corporate reporting.
As DBP-ready infrastructures mature - including semantic models, digital twins, sovereign data connectors, and traceability systems developed under BASE - companies gain access to a real-time data layer that extends far beyond compliance. Several BASE actors have already begun using DBP-aligned data for:
- Supplier benchmarking
- OPEX reduction
- Circular business model design & development
- Exploitation planning and market positioning
- Energy optimisation in manufacturing
- Predictive maintenance and SoX monitoring through Battery Performance, Durability, and Safety Indicators
- Second-life profitability modelling
This is a profound shift. Instead of building sustainability reports around corporate narratives, companies build them on top of verified operational evidence. And instead of treating ESG as a yearly reporting exercise, they integrate it into daily manufacturing, procurement, and lifecycle management.
Closing Thoughts: Adopting DBP-CSRD Synergy Will Bring New Strategic Advantages
As both regulatory frameworks expand in scope and enforcement, the companies that thrive will be those that invest early in harmonised data infrastructures. The Digital Battery Passport captures evidence that is essential for CSRD - not in the abstract, but in a concrete, timestamped, lifecycle-oriented way. It provides exactly the kind of traceable, auditable, asset-linked information regulators increasingly expect.
While still in its infancy, the BASE project is demonstrating that this is not a theoretical alignment. When companies integrate DBP-ready data models, semantic standards, and digital governance tools, their ESG reporting becomes significantly more accurate, more efficient, and more credible. They gain operational value, reduce reporting costs, and strengthen their competitive position in an industry where transparency, traceability, and circularity define market leadership.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References:
Regulation (EU) 2023/1542 on batteries and waste batteries: https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
European Commission - Corporate sustainability reporting: https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en
UN Environment Programme - European Sustainability Reporting Standards (ESRS): https://www.unepfi.org/impact/interoperability/european-sustainability-reporting-standards-esrs/
BASE - What is a Digital Battery Passport?: https://base-batterypassport.com/blog/sustainability-6/what-is-a-digital-battery-passport-a-closer-look-inside-23