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Stack 1: Core Metrics

Missing ESG Data: How Agricultural Operations Respond Honestly

You opened the buyer questionnaire and half the fields ask for data you don't have. That's normal. Here's how to categorize the gaps, use accepted estimation methods, and respond credibly—without making things up.

Every agricultural operation that receives its first ESG questionnaire hits the same wall: questions asking for data that simply doesn't exist in any file, spreadsheet, or shoebox on the farm. Soil organic carbon levels. Scope 3 emissions from purchased feed. Biodiversity baseline surveys. Methane per livestock unit.

The instinct is either to panic, to leave every unknown field blank, or to fill them with numbers that sound plausible. All three responses are wrong. There is a better way, and it starts with understanding that “missing data” isn't a single category. What's missing on your farm falls into four distinct buckets—and each one has a different, honest response.

The Four Categories of Missing Farm Data

Before you answer a single question, walk through the questionnaire and sort every gap into one of these categories. It changes how you respond to each one.

Category 1: Data That Exists but Hasn't Been Gathered

This is the largest category for most farms—and the most encouraging one. The information exists somewhere in your operation; it just hasn't been pulled together for ESG purposes.

  • Fuel receipts sitting with your accountant. Your diesel consumption is recorded in invoices from your fuel supplier. It's in your farm accounts. Nobody has summed it into an annual total and converted it to CO2e—but the raw data is there.
  • Fertilizer records in your spray logs. If you keep spray records (and you're legally required to in most jurisdictions), your nitrogen application data exists. It just needs extracting and totalling.
  • Livestock numbers in movement records. Your herd/flock numbers are in your movement records, your assurance audits, and your vet's files. Annual averages can be calculated from these.
  • Electricity use on your utility bills. Total kWh is printed on every invoice. It just needs compiling for the reporting period.
  • Training records in filing cabinets. Sprayer certificates (PA1/PA2), chainsaw qualifications, first aid training—these exist as certificates somewhere on the farm.

The honest response for this category: provide the data. It takes time to collect, but the information is available. Most farms find that 50-70% of what a questionnaire asks for falls into this bucket.

Category 2: Data That Has Never Been Tracked

This is the genuinely missing data. Your farm has never measured it because nobody asked before and you had no reason to.

  • Biodiversity baseline surveys. You may know you have hedgerows and a pond, but you've never formally documented habitat features or species counts.
  • Soil organic carbon measurements. Standard soil tests cover pH, P, and K. Organic matter or organic carbon testing is less common and often not included in routine analyses.
  • Scope 3 emissions from purchased feed. You buy compound feed or straights. You know the tonnage. But the carbon footprint of that feed's production? That's data your feed supplier would need to provide.
  • Water consumption volumes. If you're on mains water, bills show volume. If you abstract from a borehole or watercourse, you may have an abstraction license but no meter.

The honest response: acknowledge the gap clearly. “We do not currently track soil organic carbon levels. We plan to include organic matter analysis in our next soil testing cycle.” This is far better than a blank field or a fabricated number.

Category 3: Data That Is Genuinely Not Applicable

ESG questionnaires are written for general agricultural operations. Many questions simply don't apply to your specific farm type.

  • Crop farms with no livestock: Livestock methane questions, manure management, animal welfare policies—all genuinely not applicable.
  • Pastoral operations with no arable: Pesticide application data, crop rotation details, harvest yield records—not applicable.
  • Dryland farms with no irrigation: Water abstraction volumes, irrigation efficiency metrics—not applicable.
  • Family operations with no employees: Workforce diversity statistics, employee grievance mechanisms, HR policies—not applicable in the traditional sense.

The honest response: mark the field “Not applicable” with a brief explanation. “Not applicable—arable operation with no livestock.” This shows you understood the question and made a deliberate assessment, not that you skipped it.

Category 4: Data You Can Estimate Using Accepted Methods

This is the category many farms overlook—and it's the one that transforms a patchy response into a credible one. You have enough information to calculate a reasonable estimate using published methods.

  • Livestock methane. You know your animal numbers by type. You've never calculated methane emissions. But the IPCC publishes Tier 1 default emission factors per head by species and region. Multiply and you have a defensible estimate.
  • Fertilizer N2O. You know how much nitrogen you applied. National inventory guidelines provide emission factors per kg of N applied. The calculation is straightforward.
  • Diesel CO2. You know your annual diesel consumption in litres. The emission factor (2.68 kg CO2 per litre of diesel) is standard.
  • Electricity CO2. You know your kWh. Your country's grid emission factor converts this to CO2e.

The honest response: provide the estimate and state your methodology. “Estimated using IPCC Tier 1 default factors. Based on an annual average of 180 dairy cows.” Buyers and auditors accept this approach because it uses internationally recognised methods.

Accepted Estimation Methods for Farm Emissions

When you don't have directly measured data, these are the estimation approaches that ESG frameworks and buyers recognise as credible.

IPCC Tier 1 factors per livestock head. The Intergovernmental Panel on Climate Change publishes default methane emission factors for every livestock type: dairy cattle, beef cattle, sheep, pigs, poultry, goats. These vary by region (Western Europe, Eastern Europe, etc.). Tier 1 is the simplest level—a single factor per animal per year. It's not precise for your specific herd, but it's the accepted starting point.

National inventory factors for fertilizer N2O. Each country publishes national greenhouse gas inventory reports that include emission factors for nitrous oxide from applied nitrogen. These account for direct emissions (N2O released from soil after fertilizer application) and indirect emissions (from leaching and volatilisation).

Regional average fuel consumption per hectare. If your fuel records are incomplete, industry benchmarks exist for diesel use per hectare by crop type and farming system. These are less accurate than your actual records but better than zero.

Farm benchmarking data. Organisations like AHDB in the UK, Teagasc in Ireland, and equivalent bodies across Europe publish average resource-use figures for different farm types. These provide reasonable estimates when farm-specific data is unavailable.

The hierarchy is clear: measured data is best, farm-specific estimates are next, regional averages are acceptable, and acknowledged gaps are better than fabricated precision.

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What NOT to Do with Missing Data

The mistakes farms make with data gaps are predictable and avoidable. Each one damages credibility more than the gap itself would.

Don't Claim Zero Emissions Because You're a “Natural” Farm

This happens more than you'd expect. A farm that hasn't calculated emissions reports zero. The reasoning goes: “We're a small family farm, we work with nature, we can't have significant emissions.”

Every farm has emissions. Livestock produce methane. Fertilizer application releases nitrous oxide. Machinery burns diesel. Even a well-managed organic farm has a carbon footprint. Reporting zero tells the buyer either that you don't understand what's being asked or that you're being dishonest. Neither builds trust.

Don't Ignore Livestock Methane

On a ruminant operation, enteric fermentation is typically 50-70% of total Scope 1 emissions. Omitting it is like a factory omitting its largest energy source. If the questionnaire asks about greenhouse gas emissions and you have cattle or sheep, methane must be addressed.

Even if you can't provide a precise figure, an IPCC Tier 1 estimate based on your herd size is expected. The calculation takes minutes: number of animals multiplied by the default factor for your livestock type. There is no defensible reason to skip it.

Don't Upload Generic Policy Templates

When questionnaires ask for an environmental policy or sustainability strategy, do not download a template from the internet, put your farm name on it, and upload it. Auditors and experienced buyers recognise these immediately. The language is generic, the commitments are vague, and the content doesn't reflect anything about your actual operation.

A two-paragraph document that honestly describes what your farm actually does—and what you plan to improve—is worth more than ten pages of borrowed corporate language. If you don't have a formal policy, say so. Then describe your practices.

Don't Leave Fields Blank Without Explanation

A blank field is ambiguous. It could mean “not applicable,” “don't know,” “refused to answer,” or “missed this question.” The buyer can't tell the difference. Always indicate why a field is empty: not applicable, not currently tracked, or under development.

Building a Gap-Closing Plan

Once you've categorised your missing data, you have a natural improvement roadmap.

Immediate wins (this month): Gather Category 1 data—the information that already exists but hasn't been compiled. Call your accountant for fuel totals. Pull your spray logs for nitrogen applied. Get your electricity bills for the reporting period.

Quick estimates (this quarter): Calculate Category 4 estimates using IPCC factors. Livestock methane, fertilizer N2O, diesel CO2, and electricity CO2 can all be estimated from data you already have.

Data infrastructure (this year): Start tracking Category 2 items. Add organic matter to your next soil test. Install a water meter on your borehole. Begin a simple biodiversity log of habitat features. Set up a monthly fuel recording system.

Ongoing improvement (years 2-3): Move from Tier 1 defaults to Tier 2 calculations using farm-specific data. Replace regional averages with your actual measurements. Build a track record that shows year-over-year improvement.

How to Communicate Gaps Professionally

The language you use matters. Here are examples of how to frame missing data in ways that demonstrate competence rather than carelessness.

Instead of leaving a field blank: “Not currently tracked. Establishing monitoring for FY2026.”

Instead of guessing: “Estimated at 485 tonnes CO2e using IPCC Tier 1 default factors for 180 dairy cows (Western Europe region).”

Instead of “zero”: “No formal biodiversity survey conducted. The farm includes approximately 3.2 km of managed hedgerows, two farm ponds, and 4 hectares of environmental stewardship margins. Baseline survey planned for 2026.”

Instead of “not applicable” without context: “Not applicable—300-hectare arable operation with no livestock enterprises.”

Each of these responses shows the buyer that you understand the question, you've made a genuine assessment, and you have a plan. That's what builds long-term credibility—not perfection in year one.

The Stack 1 Perspective

Missing data is the starting condition for every farm that takes measurement seriously. Stack 1—Core Metrics—is not about having all the answers on day one. It's about knowing what you know, what you don't know, and what you can defensibly estimate.

The farms that handle data gaps well share a common trait: they treat their first ESG response as a diagnostic, not an exam. They use it to identify where their data infrastructure needs building. They document their methodology. They create a plan to close gaps over time.

Next year, when the same questionnaire arrives, most of those gaps will be filled. The year after, you'll be providing measured data where you once provided estimates, and estimates where you once had blanks. That trajectory matters more to buyers than any individual number.

Turn data gaps into a measurement plan

Every farm starts with missing data. Stack 1 of the Five Stacks Framework helps you categorise what you have, estimate what you can, and build the infrastructure to close gaps systematically—so next year's response is stronger than this year's.

Explore Stack 1: Core Metrics →
Stack 1: Core MetricsCSRD & ESG ComplianceCSRDESGsustainability reportingVSMEagricultural compliancemissing