ESG at Heineken: What breweries can learn from the 2026 sustainability report for their own CSRD obligations

The Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464) has required large capital market-oriented companies to report in accordance with the European Sustainability Reporting Standards (ESRS) since the 2024 financial year. Heineken N.V. belongs to the first wave of reporters and has prepared the 2026 sustainability report entirely in accordance with ESRS 1 and 2 as well as the topic-related standards E1 to E5, S1 to S4 and G1. This is the first time that a global brewing company has a consistent, auditable data set that can serve as a benchmark for medium-sized companies. For DACH breweries with corporate customers or lender requirements, the Heineken reporting is a concrete benchmark against which their own preparation can be measured.

This article analyses the structure of the Heineken report, the central materiality topics (water, climate protection, supply chain care), the double materiality methodology according to ESRS 1 and the conclusions that medium-sized breweries and beverage manufacturers in the DACH region can draw for their own Can derive CSRD obligation. You will learn which data points are typically underestimated, how an ESG officer structures the preparations, what role a compliance platform plays and how LkSG and VerpackG can be operationally connected to the CSRD. The article does not replace legal advice, but provides reliable guidance for strategic planning for the next two financial years. The appointment certificate, signed, filed, verifiable.

The CSRD has been in force since January 5, 2023 and was incorporated into the HGB in Germany through the CSRD Implementation Act of March 6, 2026, with the new §§ 289b ff. HGB for the sustainability report. The European Sustainability Reporting Standards (ESRS) became binding through Delegated Regulation (EU) 2023/2772. Heineken N.V. As a capital market-oriented company with more than 500 employees, it falls into the first wave of applications and had to report according to ESRS for the first time for the 2024 financial year.

In terms of content, the ESRS requires a report in five blocks. Firstly, a general part according to ESRS 1 (General Requirements) and ESRS 2 (General Information). Second, environmental issues (E1 climate, E2 pollution, E3 water, E4 biodiversity, E5 circular economy). Third, social (S1 own workforce, S2 value chain, S3 affected communities, S4 consumers). Fourth, governance (G1 business behaviour). Fifth, the report must be checked by an auditor (limited assurance, reasonable assurance from 2028).

Heineken also uses the GRI standards and the TCFD recommendations, which increases connectivity. The report is particularly instructive for medium-sized breweries because it shows the materiality analysis, the KPI logic and the data structure that an ESG sustainability officer must provide. CIVAC's compliance platform and officer-as-a-service solution provides the ESRS requirements as audit-proof templates so that even companies without an ESG staff department can systematically fulfil the catalogue of obligations. The ability to connect to financial reporting is important because the sustainability report must be integrated into the management report from the 2024 financial year and therefore shares identical reporting dates, consolidation groups and reporting obligations. The ESRS data points are also expected in an XBRL markup, increasing machine readability for investors and regulators.

Dual materiality under ESRS 1 requires companies to evaluate issues from both an internal and external perspective. First, Impact Materiality: What impact the company has on the environment and society. Second, financial materiality: What impact do environmental and social factors have on company value. A topic is essential as soon as one of the two perspectives crosses the threshold. Heineken has identified eleven topics as material in 2024.

The most important topics are climate (E1), water (E3), packaging and circular economy (E5), working conditions in its own workforce (S1), working conditions in the value chain (S2), responsible consumption (S4) and business ethics (G1). Heineken also conducted a stakeholder consultation with investors, NGOs, employees and suppliers and documented the results in a materiality matrix.

The methodology is transferable for medium-sized breweries, but the effort is lower. A materiality analysis for a regional brewery with 250 employees typically costs 25,000 to 60,000 euros, depending on the depth and external support. Anyone who manages the process internally needs a trained ESG officer with data skills, legal understanding and stakeholder experience. CIVAC offers the materiality matrix as a template in the compliance platform and supports the analysis as an officer-as-a-service. Licence the workspace for your internal representatives or have our representatives order it. Both paths end in audit-proof materiality documentation. Anyone who carries out the analysis externally should insist that the result is stored in their own workspace and not left with the consultant, otherwise the update will have to be commissioned again in the following year with double the effort. This means that methodological sovereignty remains within the company and the report can be updated even if the provider changes.

ESRS E1 requires the complete presentation of greenhouse gas emissions according to the GHG protocol, separated into Scope 1 (direct emissions from own plants), Scope 2 (electricity, heat, cooling) and Scope 3 (upstream and downstream value chain). Heineken reports around 0.9 million tonnes of CO2 equivalents in Scope 1 and 2 and around 14 million tonnes in Scope 3 for 2024. Scope 3 emissions account for over 94 percent of the carbon footprint.

Three Scope 3 categories dominate the brewery value chain. First, purchased goods and services (Cat. 1, especially malt, hops, aluminum cans, glass bottles, PET, cardboard). Second, upstream logistics (Cat. 4). Third, consumption and disposal of the products (Cat. 11 and 12). Anyone who ignores Scope 3 reports around 6 percent of the actual climate impact and is not tenable in the audit.

Heineken sets reduction targets for 2030 (50 percent absolute reduction in Scope 1 and 2, 50 percent intensity in Scope 3) and is part of the Science Based Targets Initiative (SBTi). A phased approach is recommended for medium-sized breweries: first year Scope 1 and 2 completely, second year Scope 3 with spend-based methodology, third year transition to activity data and supplier values. The CIVAC platform structures this data collection with templates from the pool of 37 ready-to-use samples and enables an audit-proof reporting basis over several years. Clear supplier communication is important because activity data typically only becomes available when the most important suppliers create their own CSRD reports, which will gradually happen between 2025 and 2027 for large packaging and logistics partners. In the transition phase, a hybrid methodology with spend-based estimates and supplier surveys is practical.

Water is the central environmental issue for breweries. The industry average is around 4 to 5 hectoliters of water per hectoliter of beer; Heineken reports a value of 2.9 hectoliters per hectoliter for 2024, with a target of 2.6 by 2030. The ESRS E3 requires reporting on water withdrawals, water consumption, discharges and water risks by location, with a particular focus on areas with high water stress according to the WRI Aqueduct.

For DACH breweries, water stress varies greatly regionally. In Brandenburg, Saxony and Lower Austria, several locations have received official restrictions on withdrawals in recent years. Anyone who does not report site-specific water data risks approval problems and cannot establish their reporting in an audit-proof manner. Heineken combines reporting with local water stewardship initiatives.

For medium-sized companies, we recommend connecting to the Alliance for Water Stewardship (AWS) standard, which allows a certified assessment. At the same time, appointment of a water protection officer in accordance with Section 64 WHG is mandatory for certain withdrawal quantities. This function does not cover CSRD reporting, but provides the operational database that flows into ESG reporting. The auditor calls, the evidence is ready. An integrated platform connects the water protection officer's operational data with the ESG officer's CSRD metrics, so that both functions work on one data source. Heineken also reports in detail the discharge quality according to BSB5, COD and nutrient loads, which for DACH breweries has to be documented operationally anyway due to the indirect discharge permits under state law and can be incorporated into ESG reporting with little additional effort. A location-specific water risk analysis every three years rounds off the reporting.

Heineken is subject to the Dutch equivalent of the German Supply Chain Due Diligence Act (LkSG), which has been in full force since January 1, 2026 and applies from the threshold of 1,000 employees in Germany. The ESRS S2 additionally requires information on working conditions, collective bargaining agreements, safety and human rights risks throughout the entire value chain. Both regimes overlap in content, but are legally separate and must be proven separately.

Three supply chains are critical for breweries. Firstly, raw materials such as malt and hops, which often come from Central Eastern or Southeast European sources. Secondly, packaging, especially aluminum from third countries. Third, logistics using subcontractors. Heineken reports over 5,500 direct suppliers in its risk assessment for 2024 and is conducting enhanced due diligence for 1,200 suppliers. The methodology follows the UN Guiding Principles Framework.

Medium-sized breweries will be subject to the LkSG from January 1, 2026 if they have 1,000 employees; above this threshold, the appointment of a human rights officer is mandatory in accordance with Section 4 Paragraph 3 LkSG. Anyone who remains below the threshold is actually indirectly affected as soon as customers subject to LkSG pass on their due diligence into the supply chain. Others run compliance like a filing cabinet. We run it like software. CIVAC provides the LkSG templates, supplier audits and management reporting line as an integrated workspace, and connects the data with CSRD reporting. The appointment certificate of the human rights officer is stored in the workspace and presented to the BAFA audit within hours. This means that both regimes can be operated from one database without creating parallel Excel lists and jeopardizing the consistency in the audit.

ESRS E5 requires information on resource efficiency, the proportion of recycled material and the circular economy. Heineken reports a share of 50 percent recycled material in aluminum cans, 55 percent in glass bottles and 30 percent in PET bottles by 2024. The target for 2030 is 70 percent recycled or reusable in the average pack mix. Programs for reusable systems and take-back are running in parallel.

In Germany, the disposable plastic fund regulation has tightened the obligations for PET manufacturers since January 1, 2026. Anyone who places single-use plastic packaging on the market must pay into a fund, the amount of which depends on the type of material. In addition, the Packaging Ordinance (VerpackG), which has been enforced much more strictly since 2026, also applies. The Central Packaging Register Office (ZSVR) checks the volume reports on a quarterly basis.

Medium-sized breweries should link their packaging strategy to ESG reporting. Anyone who reports purely operationally, without data connection to the sustainability report, loses consistency and produces discrepancies in the audit. Heineken shows how ZSVR reporting, EPR obligations in twelve countries and ESRS E5 can be bundled in one database. Licence the workspace for your internal representatives or have our representatives order it. CIVAC connects these data streams in a workspace with versioning and audit trails, so that the packaging data flows consistently into CSRD and VerpackG and there is no double maintenance. Anyone who sets reusable and disposable quotas for specific locations gains additional arguments for collective bargaining with dual systems and can better manage cost risks from the single-use plastic fund. The packaging strategy should be regularly coordinated with the purchasing and logistics departments so that recyclate goals do not fail due to delivery bottlenecks. A quarterly status meeting with purchasing, production and sales keeps the data quality high and ensures the ability to report across the entire balancing group.

ESRS G1 requires information on business ethics, corruption prevention, political engagement and supplier relationships. Heineken reports a compliance code of conduct, a group-wide whistleblower system (SpeakUp), internal training obligations and an annual compliance report to the board. This structure is directly transferable to DACH breweries.

At Heineken, a Chief Sustainability Officer (CSO) coordinates reporting at the governance level. Regional ESG officers work under the CSO and are responsible for data collection at the locations. This structure cannot be implemented 1:1 for medium-sized companies, but the logic remains: a central person is responsible, decentralized people provide data, and a platform ensures consistency. Without this triad, data gaps arise that are noticeable in the audit.

Specifically, DACH breweries should fix the following governance points. Firstly, written appointment of an ESG officer with a reporting line to management. Second, annual report to the supervisory board or advisory board. Thirdly, integrated whistleblower system according to HinSchG for 50 or more employees. Fourth, CSRD audit templates. Audit proof, documented, ESRS proof. CIVAC provides these governance building blocks in a template library with 490 audit templates, thereby ensuring that even companies without a dedicated ESG staff department systematically process the catalogue of obligations and hold up in the audit. Others run compliance like a filing cabinet. We run it like software. The board receives a clear reporting line, the auditor receives audit-proof documentation and the reporting department receives a consolidated database without media disruptions. A central audit trail facilitates the transition from limited to reasonable assurance, which is due for the first wave of applications from 2028. Anyone who establishes an audit-proof structure in the initial report avoids expensive correction cycles when tightening the audit standard.

Six concrete lessons can be learned for DACH breweries from the Heineken report. First, start with materiality analysis, not data collection. Anyone who collects data without having clarified the essential topics produces reports that are meaningless. Second, prioritise Scope 3 from the start. With Scope 1 and 2 alone, you neither meet ESRS E1 nor the expectations of lenders and investors.

Third, link water reporting to location data, not to corporate averages. Fourth consequence, operationally connect LkSG and CSRD. Both regimes require supplier data; A double survey costs between 40,000 and 120,000 euros per year and can be avoided. Fifth, build a platform rather than an Excel landscape. Excel is not audit-proof because versioning, access rights and timestamps are missing.

Sixth, appoint an ESG representative as early as possible. Experience has shown that the first two reporting cycles are the most difficult. Anyone who works without clear responsibility in this phase will have to install expensive correction cycles later, often with limited assurance findings. The external appointment of an ESG officer costs between 24,000 and 72,000 euros per year in DACH medium-sized companies and provides an immediate function with templates, reporting line and audit readiness. Ordering internally requires training and setup time, but is often cheaper in the long run. The auditor calls, the evidence is ready. Licence the workspace for your internal representatives or have our representatives order it. A hybrid constellation has proven successful, in which an internal employee takes over operational coordination and an external ESG officer bears methodological responsibility, which ensures structure and resilience at the same time.

If you, as a medium-sized brewery or beverage manufacturer, want to structure the ESG function, two paths open up. First, you licence the CIVAC workspace for your existing internal ESG and sustainability officers and use the 490 audit templates, the materiality matrix, the Scope 3 survey grid, the LkSG interface and the reporting line to management. Secondly, you hand over the function completely to CIVAC in the officer-as-a-service model with expert officers and ISO/IEC 27001:2022 certified platform.

CIVAC's compliance platform and officer-as-a-service solution bundles 25 officer roles, 93 controls according to ISO/IEC 27001:2022 and EU data residency in one Workspace. The SLA for the first order is two business days, compared to two to six weeks in the market. This means the ESG function is ready to work on time, long before the first CSRD report is due.

Turn reading into a mandate. A short request to info@civac.de with the number of employees, reporting year and location list is enough to receive a specific offer. Alternatively, you can reach the team using the contact form on civac.de. Within two working days you will receive a draft appointment certificate, an annual work plan, a materiality matrix as a template and a suggestion for the reporting line. The appointment certificate, signed, filed, verifiable. A pilot cycle based on your current financial year can be set up within four weeks and provides the first auditable data basis. On this basis, the annual materiality analysis, the Scope 1 and Scope 2 data collection as well as the first supplier inquiries for Scope 3 are then created. This creates an auditable basis within a reporting cycle that increases in data quality with each passing year.