The CSRD consulting industry quietly raised prices roughly 4x between mid-2023 and the end of 2024, and the work did not get 4x better. It did not get 2x better. A lot of it got worse, because the senior people who understood the draft ESRS are now three client-portfolios deep and the actual drafting landed on associates with a nine-month tenure. What the market is pricing is not expertise. It is panic.
Sit with that for a second, because most of the arguments that follow fall out of it.
I've seen the same Statement of Work three times in the last six months, from three different Big Four offices, with three different logos on the cover page. €127,000 for a first-year CSRD engagement at a mid-cap. €184,000 at a slightly bigger one. €230,000 at a listed industrial that was told the quote was "on the lean side, given the complexity." The complexity, in each case, was identical: one wave-1 or wave-2 entity, one value chain, one materiality assessment, one set of ESRS disclosures. The price difference was not expertise. It was how scared the buyer looked.
The numbers under the quote
Here is the part that nobody wants to say out loud. Before you can call a fee fair or unfair, you need to know what the work actually is.
The ESRS framework contains roughly 1,100 data points across the 12 topical standards. That sounds crushing until you read EFRAG's own implementation guidance, which notes that only about 265 are mandatory disclosures — the rest are conditional on your materiality assessment or voluntary. A typical mid-cap with four material topics ends up reporting somewhere between 300 and 450 data points. Call it 400.
A competent sustainability analyst — not a partner, not a manager, an analyst with two years in ESG and a laptop — can draft, evidence, and tag 10 to 20 ESRS data points per day once the materiality scope is set and the data is identified. That's 20 to 40 working days of drafting for 400 data points. Add materiality assessment, stakeholder engagement, XBRL tagging, internal review, and a limited-assurance readiness pass, and you land at 60 to 90 person-days for a first filing. Call it 75.
At the Big Four's published blended rate — the actual one, not the partner rate: roughly €220 per hour for managers, €140 per hour for seniors, and €90 per hour for staff — a 75-day engagement staffed realistically (5% partner, 15% manager, 50% senior, 30% staff) runs to about €95,000 in raw labor cost. Add 30% firm overhead and profit margin and you're at €125,000.
So the €127,000 quote is not obviously wrong. It's obviously consistent with a model. The problem is what the model includes, and more importantly what the model hides.
What the model hides is the learning curve discount that doesn't exist in the price. The same firm, on the same client, in year two, sends almost the same invoice — maybe 15% off — for work that is genuinely 60% cheaper to do. The materiality assessment is largely reusable. The data taxonomies are mapped. The disclosures are drafted. You are paying new-client prices for repeat-client work, and the industry has aligned on this politely enough that no one calls it out.
"But this is a complex regulation"
Let me steelman the other side properly, because it deserves it.
CSRD is a real piece of work. The ESRS standards are dense, internally cross-referenced, and still moving. EFRAG's implementation guidance has been revised repeatedly. National transpositions of the directive differ on assurance scope and deadlines. The Commission's February 2025 Omnibus proposal — which deferred Wave 3 to FY2028, raised the employee threshold, and narrowed the in-scope population by roughly 80% — was itself a late-stage shock that forced many companies to scrap workstreams they had already paid for. The Big Four firms absorbed that volatility. They trained teams, built methodologies, sat through the EFRAG webinars, and they have real institutional knowledge that a mid-cap finance team does not.
Double materiality is genuinely hard the first time. If you are in a regulated sector — financial services, mining, pharma, energy — the IRO identification and stakeholder engagement involve real judgment calls with real legal exposure. Assurance readiness, now that limited assurance is the day-one requirement, is not a clerical task. Someone needs to think about whether your Scope 3 category 11 methodology will survive an auditor's walkthrough.
There are scenarios where the €150,000 quote is worth it. A first-time filer in oil and gas with a contested materiality assessment, interim assurance coming in a year, and a board that needs to see "PwC" or "EY" on the signature page because their credit facility requires it — fine. Pay the money. That's not what I'm arguing against.
What I'm arguing against is the default assumption that every CSRD filer, at every scale, in every sector, needs the same engagement structure. The industry is pricing as if they do. They don't.
What a reasonable CSRD budget actually looks like
Strip out the ceremony and here is what you are paying for:
- Materiality assessment. For most mid-caps, this is a structured desk exercise plus 6 to 10 interviews. Two weeks of senior analyst time. Real cost: €8,000 to €15,000, not €38,000.
- Data collection and ESRS mapping. The bulk of the work. Largely mechanical once the scope is set. Real cost: €15,000 to €25,000 of analyst time, or zero marginal cost if the platform does it.
- Narrative drafting. EFRAG has published boilerplate that most firms quietly reuse. Real cost of a bespoke draft: €10,000 to €20,000. Real cost of a templated-then-reviewed draft: under €5,000.
- XBRL tagging. Software, not expertise. A decent platform produces compliant XBRL from the structured data you've already collected. Real marginal cost: near zero.
- Assurance readiness. Legitimately specialized. €10,000 to €25,000 for a mid-cap, and probably worth paying to a firm that is not doing the assurance itself.
That adds up to €40,000 to €80,000 for a well-run first filing, and €15,000 to €30,000 thereafter. Those are the numbers a functioning professional services market would produce. The fact that the actual market is quoting €80,000 to €250,000 for the same scope tells you the market is not functioning. It's clearing on fear, deadline pressure, and the soft collusion of three firms pricing off each other.
Year two should be dramatically cheaper than year one. In a sane market, it would be. In the current CSRD market, it often isn't, because the client doesn't know what year-two should cost and the firm has no incentive to tell them.
The second thing that should happen: unbundling. There is no operational reason that materiality assessment, data collection, narrative drafting, XBRL tagging, and assurance readiness need to be bought from the same firm in a single SoW. They are distinct workstreams with distinct skill requirements. The Big Four package them together because integrated fees are higher than the sum of their parts. A mature market would let you buy each one from the best provider, or not buy it at all when software has eaten it.
The third thing: calibration against the Omnibus reality. A lot of consulting contracts signed in late 2024 were scoped for a regulatory universe that the February 2025 Omnibus proposal significantly shrank. Many Wave 2 companies that were told they needed a €150K engagement now have until FY2027 or a raised threshold that moves them out of scope entirely. If your consultant hasn't proactively re-scoped — hasn't called and said "given Omnibus, let's cut 40% of the engagement" — that tells you what the engagement was really selling you.
Where software actually replaces the invoice
This is the paragraph where I'm supposed to name Formist. Fine, but not as a pitch — as an example of the alternative that already exists.
Formist, built by WeCarbon, is an AI-powered compliance platform that behaves like a colleague who has actually read the ESRS. You upload your annual report, energy bills, HR data, procurement spreadsheet — in any language — and it extracts the data points, drafts the disclosures with source-document citations, flags what's missing, and produces XBRL-tagged output. It handles CSRD, CBAM, GHG Protocol, EU Taxonomy, CDP, ISSB, and a dozen other frameworks under one subscription, which matters because the same datapoint feeds several of them and no one should be typing it in three times. It doesn't do the materiality judgment for you — that's still yours — but it drafts the IRO matrix so you're editing a proposal instead of a blank page.
That doesn't mean Formist replaces a Big Four assurance opinion. It doesn't. It replaces the €80,000 of junior-analyst time that used to sit underneath the assurance opinion. Those are different things, and the industry has been selling them as the same thing.
The quotable line
The CSRD consulting market is a transfer of wealth from mid-cap finance teams who don't know what the work costs to professional services firms that do. Pricing it correctly — and routing the mechanical work through software — isn't a threat to real CSRD expertise. It's the only way real CSRD expertise gets paid for what it's actually worth, instead of being used as cover for 200 hours of an associate's billable time.
Your €100,000 quote isn't a premium. It's a margin on fear. Stop paying it.
Formist is built by WeCarbon, a climate-tech company with offices in Paris, Dubai, and Shanghai. It supports CSRD/ESRS, CBAM, GHG Protocol, EU Taxonomy, CDP, ISSB, SBTi, and 15+ other sustainability frameworks.