Scottish Sea Farms: Translating materiality into CSRD reporting readiness

Building directly on the findings of its double materiality assessment, Scottish Sea Farms (SSF) continued its partnership with Simply Sustainable to undertake a Corporate Sustainability Reporting Directive (CSRD) gap analysis. While subsequent regulatory changes meant that SSF fell out of direct scope of the CSRD, the company elected to complete the gap analysis to maintain alignment with best practice and with the sustainability and reporting requirements of its owners, Lerøy Seafood Group ASA and SalMar ASA, which remain in scope due to Norwegian listing requirements. The work translated the outcomes of the materiality assessment and SSF’s strategic sustainability priorities into a focused, practical evaluation of readiness to report against the European Sustainability Reporting Standards (ESRS) disclosure requirements associated with its material topics, providing clarity on its current reporting position, supporting informed decision making and future proofing its approach to disclosure in line with group level expectations.

Conducted between August and October 2025, the gap analysis reviewed SSF’s existing policies, governance arrangements and sustainability data against the ESRS disclosure requirements linked to its material topics. Taken together, the double materiality assessment and the gap analysis established a clear and coherent pathway from identifying SSF’s most significant sustainability considerations to understanding what is required to report credibly and consistently in line with evolving expectations.

Impacts and benefits

Evaluation of SSF’s reporting readiness: Focused assessment of material disclosures for the ESRS requirement linked to its material topics, ensuring a targeted and efficient approach to CSRD readiness.
Clear view of progress and development needs: Highlighted where SSF already demonstrates strong alignment with best practice, while identifying the actions needed to enhance governance, data quality and reporting structures.
Actionable roadmap for next steps: Provided structured short, medium and long-term recommendations that support SSF in building robust, future-proof disclosure practices.

The gap analysis translated our materiality assessment into a balanced and realistic view of our readiness to report against the ESRS disclosure requirements. It set out the practical steps needed to strengthen our governance, data and disclosures in line with current best practice. Working with Simply Sustainable ensured the recommendations were sensibly prioritised and aligned with our strategic priorities, helping to position us to prepare robust, future‑proof disclosures in a landscape where standards continue to evolve.” Amanda Tresise Principal Sustainability Officer, Scottish Sea Farms

The story

As a natural continuation of the Double Materiality Assessment (DMA), SSF extended its collaboration with Simply Sustainable to complete a CSRD gap analysis, ensuring clear alignment between its identified material topics and the ESRS reporting requirements. Running from August to October 2025, the work centred on evaluating SSF’s existing policies, governance arrangements and sustainability data against the cross-cutting disclosures under ESRS 2: General Disclosures and the topical standards relevant to its material topics.

The analysis began by identifying the ESRS disclosure requirements applicable to SSF, using the outcomes of the double materiality assessment and the European Sustainability Reporting Standards as adopted by the European Commission in November 2023, which remain the most recent and authoritative version of the framework. Simply Sustainable then reviewed SSF’s existing documentation and datasets to understand the extent to which current policies, actions and data already met these requirements. Building on this, an initial gap analysis was completed to highlight areas of readiness and those requiring further refinement.

A collaborative workshop with the SSF team provided an opportunity to explore emerging findings, clarify interpretations and agree priority focus areas before the development of a phased action plan. This roadmap set out the improvements needed to strengthen SSF’s future alignment with the ESRS.

The review reflected SSF’s ongoing progress across its environmental, social, and governance commitments, while identifying opportunities to enhance governance structures, increase data transparency and ensure policies, KPIs and targets evolve in line with ESRS expectations.

Outcome

The CSRD gap analysis provided SSF with a clear and proportionate view of how its current practices align with ESRS disclosure requirements for its material topics. By building directly on the insights from the double materiality assessment, the work ensured consistency between strategic prioritisation, governance arrangements and reporting expectations.

Together, the double materiality assessment and the subsequent CSRD gap analysis provide SSF with a coherent pathway from the identification of its most significant sustainability impacts, risks and opportunities to an informed understanding of disclosure readiness. With a clear action plan in place, SSF is well positioned to strengthen governance, enhance transparency and progress confidently against the expectations of CSRD reporting. By assessing its readiness against the full requirements of the ESRS, SSF has established a robust reporting baseline that supports alignment not only with CSRD, but also with other leading sustainability reporting frameworks. This proactive, best-practice approach ensures the company is well prepared for evolving reporting expectations and demonstrates a strong commitment to high-quality sustainability disclosure, despite no longer being directly in scope of the CSRD.