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Missing ESG Data: How to Respond When You Don't Have Everything

Last updated · 14 September 2026

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The questionnaire asks for forty-seven data points. You have complete information for fifteen, partial data for ten, and the rest you have never tracked, cannot locate, or are not sure applies to you.

This is normal, particularly for a company responding to its first ESG questionnaire. Customers and platforms know it. Before answering, establish which kind of gap each missing item is, because the wording differs.

Kind of gapWhat to write
Data exists; not yet compiled"Not yet compiled for the reporting period. We expect to provide this by [date]." Then provide it.
Never tracked"Not currently tracked. We are evaluating implementation for [period]." Only if true.
Does not apply"Not applicable — [one-line reason]."
Can be estimated, not measuredThe estimate, the method, and when direct measurement starts.
Asked to guessDo not. A blank with an explanation is better than a number with no basis.

Why gaps are acceptable

Customers collect ESG data because the Corporate Sustainability Reporting Directive requires many of them to report supply chain data, including Scope 3 emissions. Their regulators and auditors want to see reasonable efforts to gather supplier data.

Reasonable effort does not mean complete data from every supplier. It means systematic outreach, documented responses, and improvement over time. A professionally presented incomplete response meets their need. Silence does not.

What matters:

  • You responded
  • What you provided is accurate, so they can use it
  • You explained what is missing and why
  • You indicated what will improve

A partial response with explanation beats a complete response with guessed numbers.

The four kinds of gap

Data that exists but has not been gathered. Energy bills exist; they have not been compiled. The HR system tracks training hours; nobody ran the report. These gaps close with time.

We have not yet compiled this data for the reporting period. We expect to provide it by [date].

Then do it.

Data never tracked. Water has never been measured separately from general utilities. Employee commuting emissions have never been calculated. The data could exist and does not.

We do not currently track this metric. We are evaluating implementation for the [year] reporting period.

Say this only if you intend to.

Data that does not apply. A service company has no manufacturing waste. A domestic supplier has no ocean shipping emissions. A B2B firm may have no consumer product end-of-life data.

Not applicable — as a professional services firm, our operations do not generate manufacturing waste.

Data that can be estimated but not measured. You know approximately how much employees drive for business but have no precise records. You can estimate waste from bin collections but have no weights.

Estimated at 2,400 km per month based on average reported mileage × employee count. Direct tracking planned for [quarter/year].

Presenting partial data

Lead with what you have. Do not open with apologies. Present the actual data first: "Our 2025 Scope 1 and Scope 2 emissions totaled 127 metric tons CO2e based on measured energy consumption." Then address what is missing.

State the method. For every number, one line on how it was calculated: "Scope 2 calculated from utility records using the 2025 DEFRA grid factor for Germany."

Mark estimates. Never mix measured and estimated data without distinction. A data quality column in a table does it:

Data qualityUse whenExample wording
MeasuredSource records exist: bills, HR exports, certificates, logs"Measured from 2025 electricity invoices."
EstimatedA reasonable basis exists but not exact records"Estimated from nine months of bills, annualized for the reporting year."
Not availableNot tracked and cannot be estimated responsibly"Not currently tracked; tracking owner and method to be defined in 2026."

Confidence levels, where the customer is sophisticated. "High confidence: Scope 2 electricity data. Medium confidence: fleet fuel (estimated from expense reports). Not available: upstream supply chain emissions."

Estimation methods customers accept

Extrapolation from partial data. Nine months of energy bills, three missing: extrapolate from the average of the months held, adjusting for seasonality. "October–December estimated from the January–September average."

Industry averages as proxies. The carbon intensity of purchased materials is unknown, but published databases give averages. Applying an average factor for steel, plastic, or transport to known quantities is accepted methodology. "Material emissions estimated using [database] average factors."

Activity-based estimation. Commuting is not tracked, but headcount is known and average commute distances are published for the region. 50 employees × 25 km × 220 working days × 0.17 kg CO2e/km. Show the calculation.

Spend-based estimation. For supply chain categories without physical data, financial data can proxy. €100,000 of professional services × a published spend factor. Lower quality than activity data; better than nothing.

Documentation is what makes an estimate usable. "Estimated" alone is useless. "Estimated based on [method]" is usable.

What not to do

Do not guess without basis. A number invented because the field cannot be blank is worse than a blank. It misleads the customer's reporting and creates audit problems.

Do not round to suspiciously clean figures. Exactly 100 metric tons CO2e or exactly €1 million reads as an estimate even when accurate. Report actual figures.

Do not hide uncertainty. If data quality is poor, say so. Customers prefer to know they are working with estimates.

Do not claim policies you do not have. If asked "Do you have an environmental policy?" and you do not, answer no. Do not upload a generic template as your own.

Do not leave questions empty. An empty field looks skipped. "Not currently tracked — under development" shows engagement.

Sample wording

Not tracked: "[Metric] is not currently tracked in our data systems. We plan to implement tracking beginning [quarter/year]."

Not applicable: "Not applicable to our business model. As a [description], we do not [activity]."

Estimated: "Estimated at [value] based on [methodology]. We are implementing direct measurement for future reporting periods."

Partial: "Complete data available for [portion]. Remaining [portion] estimated based on [approach]. Full coverage expected from [date]."

Complex gaps: "Our current systems capture Scope 1 and 2 emissions in full. Scope 3 categories [list] are not yet tracked. We are prioritizing Category 1 (purchased goods) and Category 6 (business travel) for [year] implementation."

Using the gaps to plan

The missing data is the work list. If energy questions were hard to answer, set up basic ESG tracking. If employee data was scattered across departments, establish one HR data source. If there was no environmental policy to reference, the ESG policy template guide has one to download. The free carbon calculator and water calculator show which figures to collect and turn them into the numbers questionnaires ask for.

The ESG response checklist lists what customers expect and where it usually lives. Used as the tracking list, it turns next year's response from gap-filled to complete.

Gaps in a first response are normal. Gaps in a fifth response to the same customer are a signal. Trajectory is what customers read.

Official References

Related Guides

Put this into practice

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