EDIH, EEN, Interreg: the platform for European programmes.Find out more

NFRD Directive Maturity · Non-financial information disclosure

Your non-financial disclosure practices, measured against NFRD and turned into an action plan.

10 themes, a 5-level scale. And the action that moves each level to the next.

The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.

NFRD Directive Maturity · Non-financial information disclosure

Governance of non-financial informationN1 → N5
Business model and materiality analysisN1 → N5
Policies and due diligenceN1 → N5
Non-financial risksN1 → N5

10 themes, 5-level scale.

Nordhavn Industries

53 / 100

Governance of non-financial information6484
Business model and materiality analysis5379
Policies and due diligence6182
Non-financial risks3773
IAIndustrialised: your interview notes are enough, the AI fills in the audit.

They measure their maturity with Datamensio

  • Caisse des Dépôts
  • Chambre de commerce et d'industrie
  • Docaposte
  • Enterprise Europe Network
  • EDIH Network
  • KPMG

An example

This could be your situation.

Take one company as an example: three sites, three spreadsheets, no shared answer.

01

Nobody can consolidate.

Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.

02

Three weeks, a single base.

One Directive 2014/95/EU (NFRD), transposed in France by the ordinance of 19 July 2017 (non-financial performance statement) assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.

03

Two costs avoided before being committed.

A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.

What it saved them

  • 3sites measured on the same base, instead of three questionnaires to reconcile
  • 2duplicate actions caught before the spend
  • 1committee report, with no manual rework

These figures are an example. They could be yours.

The standard imposes processes. Datamensio says where you stand.

01

The framework is already written

Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.

02

The score lands the same day

Online, by self-assessment link or in interview. Theme by theme, comparable over time.

03

The gap becomes a costed plan

Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.

04

Progress can be demonstrated

Campaign after campaign, against your target and against your own past. That is what your board asks for.

The maturity scale

One level, the next, and the action that links the two.

This mechanism, one level, the next level up, and the action that links the two, is what turns a finding into a trajectory.

Are the published key performance indicators based on documented definitions and scope?

  1. N1

    No written definitions. Indicators are reconstructed each year from files submitted by subsidiaries, with no shared rule.

  2. N2

    Definitions exist for some indicators, scattered across different documents. The scope used varies from one entity to another.

  3. N3

    A reporting protocol documents definitions, calculation methods and scope. It is circulated to contributors and generally applied.

  4. N4

    The protocol is applied by all entities, gaps and restatements are tracked and justified, multi-year comparability is checked before publication.

  5. N5

    The protocol is revised as requirements and independent third-party auditor comments evolve, with a revision history and impact analysis on published series.

Action to move from L2 to L3

Consolidate existing definitions into a single reporting protocol, attach it to the annual collection campaign and have it signed off by the finance department at the launch of the campaign.

« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Chambre de commerce et d'industrie

Director, CCI 94CCI Île-de-France

« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Interreg Danube Region

Maja SucekChief Operating Officer, Interreg Danube

Take your first measurementon NFRD.

What this framework covers

The NFRD, Directive 2014/95/EU, amended the Accounting Directive 2013/34/EU to require a non-financial performance statement from public-interest entities with more than 500 employees. It covers four areas: environmental, social and employee matters, respect for human rights, and anti-corruption. For each, the company describes its business model, its policies and related due diligence, the outcomes achieved, the principal risks and key performance indicators. The text works on a comply-or-explain basis: where no policy exists on a given area, the company must explain why.

In practice, the difficulty lies not in drafting the report but in producing the underlying information. The NFRD sets no calculation standard, leaving each group to organise its own collection chain. Who produces the social data for foreign subsidiaries, and under what definition of scope? Are last year’s published indicators reproducible identically this year? Do the disclosed non-financial risks come from the group’s risk map, or are they reconstructed once a year for the universal registration document?

The context has shifted. CSRD, Directive (EU) 2022/2464, is progressively replacing the NFRD and introduces mandatory disclosure standards, the ESRS, a wider scope of companies and limited assurance on published information. A common mistake is to treat the NFRD as a closed matter. It remains the foundation on which existing teams build, and the maturity level reached on its requirements largely determines the effort needed to move to the ESRS. An NFRD assessment therefore serves as both a stocktake and a starting point.

A compliance audit asks a binary question: does the statement include the required disclosures, yes or no. A maturity assessment asks a different one: what level of control applies at each link, from collection to reporting, and what specific action moves it up a level. A report published on time may still rest on untraceable manual extractions. This distinction reshapes the priorities of the action plan.

In Datamensio, the framework is ready to use and adaptable. The AI adjusts themes, questions and levels to your sector and consolidation scope, or builds a variant from your own documents: existing statement, collection procedures, risk map.

Reference standard: Directive 2014/95/EU (NFRD), transposed in France by the ordinance of 19 July 2017 (non-financial performance statement)

The themes assessed

  • Governance of non-financial information

    Reporting line for the subject, roles and responsibilities, involvement of the board and audit committee, sign-off of the statement before publication.

  • Business model and materiality analysis

    Description of the business model, method for selecting disclosed issues, stakeholder consultation, traceability of the choices made.

  • Policies and due diligence

    Existence of formalised policies per area, due diligence procedures, coverage of the value chain and suppliers, application of the comply-or-explain principle.

  • Non-financial risks

    Identification of principal risks, alignment with the group’s risk map, impact assessment, mitigation measures and follow-up.

  • Key performance indicators

    Documented definition of each indicator, calculation method, consolidation scope, multi-year comparability, restatements and justification.

  • Environment

    Greenhouse gas emissions and scopes covered, energy consumption, water, waste, biodiversity, treatment of climate change.

  • Social and employee matters

    Employment and headcount, social dialogue, health and safety, training, diversity and equal treatment, data by entity and by country.

  • Human rights and anti-corruption

    Respect for human rights in operations and the supply chain, anti-corruption measures, internal whistleblowing, training for exposed populations.

  • Collection, systems and internal control

    Collection tools, degree of automation, audit trail, consistency checks, preparation for verification by the independent third-party auditor.

  • Publication and CSRD trajectory

    Format and place of publication, accessibility, consistency with other communications, gaps identified against the ESRS and convergence plan.

A short version of the framework is available for the online self-assessment.

Frequently asked questions

Is the NFRD certifiable?

No. It is a European directive transposed into national law, requiring publication and, in France, verification by an independent third-party auditor. The Datamensio assessment measures the maturity of your practices and prepares for this verification, it does not issue any certificate.

Isn’t the NFRD being replaced by CSRD?

CSRD is progressively succeeding it, with mandatory disclosure standards and a wider scope. NFRD requirements remain the foundation of existing arrangements. Measuring your NFRD maturity helps identify what is reusable and what needs rebuilding for the ESRS.

What is the difference between this assessment and a compliance audit?

An audit checks for the presence of required disclosures and concludes with a gap or a pass. The assessment places each practice on a progressive scale and points to the action that moves it up a level. The assessment prepares for the audit, the audit validates it.

How long does the assessment take?

The short version can be completed in a single session by a contributor familiar with the file. The full version, run collaboratively, spans one to two weeks: most of the time goes into gathering input from the CSR, finance, HR and procurement teams.

Can the framework be adapted to our sector and scope?

Yes. Themes, questions and levels can all be modified, and the AI produces a variant based on your existing statement or collection procedures. You can also add themes specific to your business.

How do we compare several entities within the group?

The same framework is rolled out to each business unit, then scores are compared by theme. The internal benchmark shows practice gaps between subsidiaries, and comparison with previous campaigns measures progress.

What does the assessment produce at the end?

A score per theme, a gap against the chosen target, and the action plan derived from that gap. The AI groups the actions into a prioritised roadmap, and the service catalogue offers a solution costed in time, budget and score impact for each item.

Where is the data hosted?

In France, at OVH, with backup at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.

Take your first measurementon NFRD.