Corporate Sustainability Reporting Directive (CSRD)

The Corporate Sustainability Reporting Directive (CSRD) is a new European Union (EU) legislation that requires all large companies to publish regular reports on their environmental and social impact activities.

The CSRD supports investors, consumers, policymakers, and other stakeholders in evaluating large companies' non-financial performance. Thus, it encourages these companies to develop more responsible business approaches. For instance, it radically transforms companies' scope of sustainability reporting. With the CSRD, the European Commission defines a common reporting framework for non-financial data for the first time.

On November 28, 2022, the European Union Council approved the Corporate Sustainability Reporting Directive (CSRD). Following the Council's approval of the European Parliament's position, the CSRD legislative act was adopted.

Reporting is happening soon: companies must submit their CSRD-compliant report by January 1, 2025, for the 2024 financial year (FY). Complying with the CSRD will be challenging for companies, as data collection and third-party auditing require time and resources.

If your company is not familiar (yet) with this regulation, you are wondering, "Does my company need to comply?" It is time to become an expert on the topic. We have you covered on that side.

What is the Corporate Sustainability Reporting Directive (CSRD)?

• The European Commission adopted the ambitious and comprehensive Sustainable Finance Package on April 21, 2021, to help improve money flow towards sustainable activities across the European Union. One of the proposed measures within the package is the Corporate Sustainability Reporting Directive (CSRD).
• The CSRD has been officially adopted by the European Union Council and entered into force on January 5, 2023.
• The CSRD extends the scope and reporting requirements of the previous Non-Financial Reporting Directive (NFRD). Since 2018, this regulatory framework has mandated that sizeable public interest entities report on their sustainability performance.
• With its new requirements, the CSRD aims to ensure that businesses report reliable and comparable sustainability information so that investors can re-orient investments towards more sustainable technologies and industries.

Which companies have to comply with the CSRD?

• The CSRD expands the sustainability reporting requirement to a broader range of companies compared to the previous Non-Financial Reporting Directive (NFRD).
• Whereas the NFRD only applied to companies with more than 500 employees, the CSRD extends to large companies defined as those with over 250 employees €50M turnover, and €25M in total assets.
• Under the CSRD, all listed companies (except micro-enterprises) must report their sustainability performance.
• The enforcement of the CSRD means that around 50,000 companies across the EU, which account for 75% of all EU companies' turnover, will be required to adhere to detailed EU sustainability reporting standards.
• Non-European companies with branches or subsidiaries in the EU and a net turnover of €150M or more within the EU will also be required to comply with the CSRD, but this requirement will be enforced later.

To learn more about the threshold of the CSRD, read our dedicated content.

Detailed disclosures under the Corporate Sustainability Reporting Directive (CSRD)

The CSRD widens the range of businesses required to report on their sustainability and elevates the level of disclosure required. In addition to requirements defined by the NFRD, companies must provide detailed reports on the following:

• Environmental protection measures: Businesses must disclose specific initiatives to reduce their environmental footprint, including resource conservation and pollution prevention strategies.
• Social responsibility and treatment of employees: This includes everything from employee health and safety protocols to employee benefits and company culture.
• Respect for human rights: Companies must discuss their policies on human rights and how they ensure these rights are not violated within their operations.
• Anti-corruption and bribery measures: Businesses must explain their strategies to prevent corruption and bribery, including corporate governance measures and ethics training programs.
• Diversity on company boards: The CSRD requires companies to provide a detailed breakdown of the diversity of their board members, focusing on aspects such as gender, age, and nationality.

Businesses must also start reporting how sustainability risks might affect their performance.

• While the EU provides voluntary reporting guidelines for NFRD reports, the CSRD introduces more detailed reporting requirements and a requirement to report according to EU sustainability reporting standards.
• The CSRD reporting aligns with the Sustainable Finance Disclosure Regulation (SFRD) and the EU Taxonomy. 

Learn more about the ESRS with our detailed whitepaper: Understanding the European Sustainability Reporting Standard (ESRS).

Timeline of implementation for the CSRD

The CSRD officially entered into force on January 5, 2023, after receiving the final approval from the European Union Council on November 28, 2022.

The phased implementation of the Directive will occur as follows:

• End of 2023: EU Member States must adopt the EU Directive into national law.
• January 1, 2024: Companies within the scope of CSRD and currently reporting under the NFRD will be obliged to report their FY 2024 data in 2025. As of the beginning of 2024, all other large EU companies within the scope of CSRD are obliged to report.
• January 1, 2025: Businesses already subject to the NFRD must start reporting in the financial year 2024.‍
• January 1, 2026: SMEs listed on a regulated market (no micro-enterprises) must report for FY 2025 (but under less stringent reporting requirements).
• January 1, 2028: Small and medium enterprises, small and non-complex credit institutions, and captive insurance undertakings will have to start reporting for 2027, with a further possibility of voluntary opt-out until 2028. The reporting standards for SMEs will be lighter.‍
• January 1, 2029: Non-European companies that have branches or subsidiaries in the EU with a net turnover of €150M in the EU will have to start reporting.

Learn more about the timeline of the CSRD and the due diligence obligations related to the CSRD.

Can companies get sanctioned if they are not complying?

It is still being determined precisely when the EU Commission will sanction businesses failing to comply with the CSRD. According to the Commission's requirements within the Directive, the sanctions can be expected to be significant.

The nature of the sanctions and total cost will depend on the different Member States. For example, suppose German businesses must report compliance with the German version of the CSRD. In that case, they face fines up to the highest amount: €10M or 5 % of the company's total annual turnover or twice the amount of the profits gained or losses avoided because of the breach.

On the other hand, French businesses face no fines if they don't report according to the CSRD unless an interested party asks to disclose the non-financial information. Subsequently, a judge can impose financial penalties if it is not available.

Preparing your business for the Corporate Sustainability Reporting Directive (CSRD)

The CSRD's implications for businesses are immense, affecting everything from operations to strategic planning. Given the short timeline, companies must start preparing for the CSRD. By starting the data collection process early, businesses can ensure they are ready to meet these new requirements when the time comes.

Given the CSRD's comprehensive nature, businesses should seek guidance from policy experts. These experts can provide valuable insights into what the CSRD means for their business and help them develop an effective compliance strategy.

Start reporting on your impact. Contact our policy experts to discover our CSRD reporting solutions.