The Corporate Sustainability Reporting Directive (CSRD)

CSRD transforms sustainability reporting, obligating diverse businesses. Compliance aids reputation, avoids penalties, and aligns strategies with sustainability goals.

As of January 5, 2023, the Corporate Sustainability Reporting Directive (CSRD) is in effect, enhancing social and environmental reporting for businesses. It broadens reporting requirements to include more large companies and listed SMEs. The CSRD ensures vital information is available for stakeholders and investors to evaluate social, environmental, and financial aspects efficiently. Additionally, it aims to reduce reporting costs by streamlining information.

Compliance Requirements and Implications

The Corporate Sustainability Reporting Directive (CSRD) is one such regulation that demands your attention. Let’s learn more about the compliance requirements and implications of the CSRD, helping you navigate the complexities of this directive effectively.

Compliance Requirements

The CSRD, an extension of the existing Non-Financial Reporting Directive (NFRD), brings forth several key compliance requirements:

a) Expanded Scope: Unlike the NFRD, which primarily applied to large public-interest entities, the CSRD casts a wider net. It encompasses a broader range of companies, including small and medium-sized enterprises (SMEs). Mid-sized organizations are no longer exempt, and the thresholds for reporting have been lowered. This means that more businesses must disclose their sustainability information.

b) Mandatory Sustainability Reporting: Under the CSRD, sustainability reporting becomes a mandatory obligation for companies. It's no longer a voluntary initiative. The directive defines specific sustainability information that must be reported, including environmental, social, and governance (ESG) metrics.

c) Digital Reporting: The CSRD introduces a shift towards digital reporting. Companies will need to use European Single Electronic Format (ESEF) for sustainability reports. This shift aims to enhance transparency and accessibility of sustainability data.

Implications of Non-Compliance

Understanding the implications of non-compliance is essential. Failing to adhere to CSRD requirements can have far-reaching consequences:

a) Legal Penalties: The CSRD comes with the teeth to enforce compliance. Companies that do not meet the reporting obligations may face legal penalties, fines, or even bans from accessing EU markets. Such penalties can directly impact your organization's financial health and market access.

b) Reputational Risks: Beyond legal ramifications, non-compliance poses significant reputational risks. In an era where consumers and investors increasingly prioritize sustainability, a failure to report transparently can damage your brand's reputation. Negative publicity can lead to loss of customers and investors.

c) Competitive Disadvantage: Companies that embrace sustainability reporting and align their strategies with ESG goals stand to gain a competitive edge. Failing to comply with the CSRD puts your organization at a disadvantage in terms of attracting investors and customers who value sustainability commitments.

Strategic Considerations: Even if your organization doesn't meet the CSRD's criteria for mandatory reporting, it's essential to consider voluntary sustainability reporting. Such reporting can enhance transparency, attract investors, and improve brand reputation

Ensuring Efficient Compliance

To efficiently navigate the CSRD compliance landscape, consider these strategies:

a) Early Assessment: Begin by conducting a thorough assessment of your organization's current reporting capabilities and data collection processes. Identify gaps and areas that require improvement.

b) Invest in Data Management: Robust data collection and management systems are critical. Explore data automation tools and software solutions to streamline the process and ensure data accuracy.

c) Internal Controls: Establish internal controls to guarantee data accuracy and compliance. Designate responsible teams or individuals within your organization to oversee sustainability reporting.

d) External Expertise: If necessary, seek external expertise from sustainability consultants or auditing firms. They can provide guidance on compliance and help ensure your reports meet the CSRD's standards.

Who Must Comply 

It's crucial to understand which companies fall under the purview of this directive. The CSRD brings about significant changes in terms of the scope of companies required to comply. Here, we clarify who must adhere to CSRD reporting requirements.

Expanded Scope

The CSRD significantly broadens the range of companies obligated to report on their sustainability performance. Key changes include:

a) Extension Beyond Public-Interest Entities: While the previous Non-Financial Reporting Directive (NFRD) primarily applied to public-interest entities, the CSRD extends its reach to encompass a wider array of entities.

b) Lowered Thresholds: One of the most noteworthy changes is the lowering of reporting thresholds. Under the CSRD, smaller and medium-sized entities may now meet the criteria for reporting, bringing more companies into compliance.

Threshold Criteria

To determine if your company is subject to CSRD compliance, consider the following criteria:

a) Size: The CSRD includes "large" companies, defined as those exceeding at least two of the following thresholds for two consecutive financial years:

  • €20 million in total assets
  • €40 million in net turnover
  • An average of 250 employees during the financial year

b) Listed on EU Markets: Companies whose securities are traded on EU-regulated markets, regardless of size, must comply with CSRD requirements.

c) Non-Financial Undertakings: Non-financial undertakings (i.e., organizations that provide goods or services) with over 500 employees, exceeding at least one of the financial thresholds mentioned, must report under CSRD.

d) Qualifying Companies: Certain qualifying companies, which may not meet the size criteria but have been designated by EU member states as significant in terms of their environmental and social impact, also fall under CSRD compliance.

Regardless of your company's size, proactive preparation for CSRD compliance is advisable. Engage in early assessment, data management improvements, and alignment of sustainability with your business strategy.

Compliance Phases and Deadlines

Understanding the timeline for the implementation of the Corporate Sustainability Reporting Directive (CSRD) is essential for businesses aiming to navigate this regulatory landscape effectively. 

The First Phase: January 1, 2024

Companies Affected: Large Companies Subject to NFDR

The CSRD's journey begins with large companies already subject to the Non-Financial Reporting Directive (NFDR). These companies, typically boasting over 500 employees, must transition to CSRD compliance on January 1, 2024. This marks the commencement of their reporting under CSRD requirements for the fiscal year 2024. Their inaugural CSRD reports are set to be published in 2025.

The Second Phase: January 1, 2025

Companies Affected: Expansion to New Companies

The second phase broadens the CSRD's scope. Starting on January 1, 2025, large companies that previously fell outside the NFDR's purview are now obligated to comply with CSRD requirements. To fall under this category, these companies must meet at least two of the following criteria: more than 250 employees, 40 million EUR in turnover, or 20 million EUR in total assets. Their reporting responsibilities under CSRD commence in 2025, with reports slated for publication in 2026.

The Third Phase: January 1, 2026

Companies Affected: Inclusion of SMEs

As of January 1, 2026, the CSRD extends its reach to small and medium-sized enterprises (SMEs) listed on EU-regulated markets. These SMEs must exceed at least two of the following thresholds: more than 10 employees, more than 700,000 EUR in net turnover, or more than 350,000 EUR in total assets. It's noteworthy that CSRD does not encompass enterprises with fewer than 10 employees or below 2 million EUR in net turnover.

SMEs and other small and non-complex institutions must implement the CSRD and align with the European Single Electronic Reporting Format (ESEF) starting from the financial year 2026. However, they retain the option to opt out of the reporting rules until January 1, 2028.

The Fourth Phase: January 1, 2028

Companies Affected: Non-EU Country Companies

The CSRD's reach extends beyond EU borders on January 1, 2028. Non-European companies will be subject to CSRD if they meet specific criteria, including a net turnover exceeding 150 million EUR in the EU and at least one subsidiary or branch within the EU.

Understanding the phased implementation of the CSRD is vital, as it helps in planning and ensuring compliance within the stipulated timelines. Stay informed and prepared to meet the evolving requirements of the CSRD as it progresses through these phases.

Preparing for CSRD Compliance

Strategic Steps for Readiness

Prepare your business for CSRD compliance with these essential steps:

  • Assess Your Current State: Evaluate your current sustainability reporting practices.
  • Data Management: Invest in data management systems for accurate reporting.
  • Align with Business Goals: Link sustainability initiatives with your strategic objectives.
  • Early Compliance Strategy: Plan for the CSRD's specific compliance phase.
  • Stakeholder Engagement: Engage with stakeholders transparently.
  • Sustainability Integration: Leverage sustainability for competitive advantage.
  • Governance and Risk Management: Establish oversight and manage sustainability risks.
  • Compliance Tools: Consider sustainability management software.
  • Continuous Improvement: Monitor progress and adapt.
  • Resource Allocation: Dedicate resources for sustainability.
  • Expert Guidance: Seek expert advice for compliance.
  • Cultural Shift: Foster a culture of sustainability.
  • Early Awareness for SMEs: SMEs should familiarize themselves with CSRD requirements ahead of their compliance phase.

Lead the way in sustainability with Carbon Analytics. Align with the CSRD and simplify your sustainability reporting. Connect with our experts for tailored solutions to track and report on your carbon footprint. Contact us today!

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