How to Build ESG Data Collection Without a Sustainability Team

Who this is for

SMEs and mid-sized companies with no dedicated sustainability role, who need to start producing ESG data but can't justify a new hire or an enterprise platform yet.

Plain explanation

The data ESG reporting needs — energy use, water, waste, safety incidents, worker demographics, governance policies — almost always already exists somewhere in your company. It's just scattered: electricity bills sit with accounts, safety logs sit with HR or operations, fuel purchases sit with procurement or admin. The job isn't to invent new measurement systems from scratch; it's to identify who already holds each number and build a light process to collect it on a schedule.

India specifics

Map your data to the 9 NGRBC principles (see our plain-English guide) as an organizing structure, since that's what BRSR and most customer questionnaires end up asking about anyway:

Assign one owner per data category, not one person for everything. A single "ESG lead" who has to personally track down every number from every department will burn out or produce unreliable data. A distributed model — where HR owns its numbers, accounts owns its numbers, and one coordinator assembles the final report — scales much better with a small team.

Start with a spreadsheet, not software. A shared spreadsheet with one tab per principle, updated quarterly or annually by the relevant owner, is a completely legitimate system for a first year or two. Enterprise ESG platforms solve problems (multi-entity consolidation, automated calculations, audit trails) that most SMEs don't have yet — don't pay for complexity you don't need.

Worked example

A 60-person food processing company with no sustainability role sets up its first data collection cycle:

• HR is asked to pull: total headcount, gender split, safety incidents, and average wages by category — a one-page form, filled once a quarter.
• Accounts is asked to pull: annual electricity consumption (kWh) from utility bills, and annual diesel purchases for the backup generator.
• Admin is asked to pull: water bills and any waste disposal records.
• The owner/founder personally confirms whether written policies exist (anti-bribery, code of conduct) — usually a yes/no plus a document link, not new work.

One person — often the finance head or an operations manager, not a dedicated ESG hire — spends a few hours each quarter compiling these into a single spreadsheet. By year-end, the company has a full year of real data ready for a BRSR filing, a customer questionnaire, or its first materiality assessment (see our beginner's guide) — without ever hiring a sustainability specialist.

Checklist

• Map each ESG data category to the department or person who already holds it — don't assume you need to collect anything from scratch.
• Assign one clear owner per category, not one person responsible for everything.
• Set a fixed collection schedule (quarterly is common) rather than scrambling once a year right before a deadline.
• Use a shared spreadsheet as your first system — only consider dedicated software once manual collection genuinely breaks down.
• Keep source documents (bills, logs) attached or referenced — an assessor or customer may ask where a number came from.

What to do next

Before building a data-collection system, it's worth confirming what you're actually building it for.

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Current as of: 22 July 2026. This is a practical operating approach, not a regulatory requirement — adapt it to your company's structure rather than following it as a fixed template.

Sources:

• GreenMinds India — BRSR reporting in India
• IMPRI — India's ESG reporting shift