Measuring and Reporting the Impact of Technology and AI on Corporate Sustainability

Practical Guide for CSRD Compliance

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How to Measure and Report the Carbon Footprint of Technology and AI under the CSRD

Artificial intelligence and digital transformation optimize processes and reduce operational emissions, but their infrastructure generates a growing carbon footprint that most companies do not account for. Model training, cloud infrastructure, connected devices, and SaaS applications emit CO₂ continuously and, until now, invisibly. The CSRD requires these to be reported with the same rigor as any other corporate emission.

The problem is twofold: existing sustainability frameworks do not include specific metrics for technology and AI, and companies lack visibility into what their digital systems actually consume. This leads to frequent reporting errors — such as accounting only for avoided emissions while ignoring those generated — which can distort the real balance by nearly 50%.

This whitepaper proposes a practical approach to address this. It explains how to build a technology asset inventory, how to apply measurement frameworks specific to software and AI (SCI, CodeCarbon), and how to integrate that data into the ESRS standards required by the directive. All of this through a 4-phase framework validated across European organizations in various sectors.

  • The document also incorporates the amendments introduced by the Omnibus I package of December 2025: New application thresholds and updated timeline — and real application cases in banking, manufacturing, and retail with verified reductions of between 24% and 43% in technology emissions over 24 months.
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