CSRD: Europe leads the way for ESG reporting

With the publication of the ESRS (European Sustainability Reporting Standards) by the EU Commission on 31 July, the CSRD is now a reality for 50,000 companies in Europe, that will have to write their first ESG report between 2025 and 2029, depending on their size and if they are listed or not.

By enlarging the scope of reporting companies, introducing double materiality, new common standards and including scope 3, CSRD creates a common reporting framework that improves the content and quality of sustainability information in the EU.

Who is subject to the CSRD?

The Directive widens the scope of the Non-Financial Reporting Directive (NFRD) adopted in 2014, that only applies to large listed companies, banks and insurance companies with more than 500 employees, i.e. approximatively 11,600 companies in EU in 2021.

The CSRD applies to:

    • Large companies which meet 2 of the following criteria:
        • > 250 employees
        • > 50 M€ in net turnover
        • > 25 M€ in total assets
    • Listed SMEs which meet two of the following criteria:
        • 10 – 249 employees
        • 900 K€ – 50M€ net turnover
        • 450 K€ – 25 M€ in total assets
    • Non-EU companies which meet the two following criteria:
        • At least one branch or subsidiary in the EU
        • > 150 M€ turnover in the EU

 

The CSRD won’t apply to:

    • Non-listed SMEs
    • Listed SMEs with financial assets on growth markets or multilateral trading facilities
    • Listed micro-enterprises which meet at least two of the following criteria:
        • 10 and less employees
        • < 900K€ in net turnover
        • < 450K€ in total assets

 

The excluded firms can and are encouraged however use the developed standards voluntarily. At eolos, we do work with companies aligning to these standards although they are not requested to. This is a great journey to mobilise the teams and trigger improvements.

The Directive widens the scope of the Non-Financial Reporting Directive (NFRD) adopted in 2014, that only applies to large listed companies, banks and insurance companies with more than 500 employees, i.e. approximatively 11,600 companies in EU in 2021.

The CSRD applies to:

Large companies which meet 2 of the following criteria:

>250 employees

>50 M€ in net turnover

>25 M€ in total assets

Listed SMEs which meet two of the following criteria:

10 – 249 employees

900 K€ – 50M€ net turnover

450 K€ – 25 M€ in total assets

Non-EU companies which meet the two following criteria:

At least one branch or subsidiary in the EU

>150 M€ turnover in the EU

The CSRD won’t apply to:

Non-listed SMEs

Listed SMEs with financial assets on growth markets or multilateral trading facilities

Listed micro-enterprises which meet at least two of the following criteria:

10 and less employees

< 900K€ in net turnover

< 450K€ in total assets

The excluded firms can and are encouraged however use the developed standards voluntarily. At eolos, we do work with companies aligning to these standards although they are not requested to. This is a great journey to mobilise the teams and trigger improvements.

From the industry, for the industry

Regulatory compliance is just the first step towards a sustainable and economic future for your company.  We translate the range of environmental regulations, integrating the specific industry targets and topics, as well as competitor and customer benchmarks. Check out our regulatory compliance page to discover how we can leverage the potential of your company

What is new with the CSRD (compared to NFRD)?

Materiality Assessment (Double Materiality)

Companies will have to report on how sustainability issues affect their business and development (“outside-in” perspective) and on the impact their activities have on people and the environment (“inside-out” perspective)

Standardisation

CSRD creates a common reporting framework that improves the content and quality of sustainability information: the European sustainability reporting standards (ESRS).

    • 2 Cross-cutting
        • ESRS 1 General requirements
        • ESRS 2 General disclosures
    • 5 Environmental:
        • ESRS E1 Climate change
        • ESRS E2 Pollution
        • ESRS E3 Water and marine resources
        • ESRS E4 Biodiversity and ecosystems
        • ESRS E5 Resource use and circular economy
    • 4 Social:
        • ESRS S1 Own workforce
        • ESRS S2 Workers in the value chain
        • ESRS S3 Affected communities
        • ESRS S4 Consumers and end-users
    • 1 Governance:
        • ESRS G1 Business conduct

Materiality Assessment (Double Materiality)

Companies will have to report on how sustainability issues affect their business and development (“outside-in” perspective) and on the impact their activities have on people and the environment (“inside-out” perspective)

Standardisation

CSRD creates a common reporting framework that improves the content and quality of sustainability information: the European sustainability reporting standards (ESRS).

2 Cross-cutting

ESRS 1 General requirements

ESRS 2 General disclosures

5 Environmental:

ESRS E1 Climate change

ESRS E2 Pollution

ESRS E3 Water and marine resources

ESRS E4 Biodiversity and ecosystems

ESRS E5 Resource use and circular economy

4 Social:

ESRS S1 Own workforce

ESRS S2 Workers in the value chain

ESRS S3 Affected communities

ESRS S4 Consumers and end-users

1 Governance:

ESRS G1 Business conduct

 

How to report?

ESG Indicators

Companies will be required to track and share their social and environmental impacts, as well as their governance practices. They will have to report on what they have put in place to contribute to the ecological transition with metrics.

Standards and digital format

The reports will have to respect precise standards, including in digital format, to facilitate the use and sharing of the information.

Audit

The reports will have to be audited and certified by an independent structure, which will verify the sincerity of the information and the presence of sustainability objectives.

Penalties

Penalties for infringements are not yet specified but will be defined by each Member State. However, the EU Commission indicated that they must be effective, proportionate and dissuasive.

On what timeline?

An application in 4 stages

The directive will come into force in 2025 and its application will take place in 4 stages:

    1. Reporting in 2025 (on the financial year 2024) for companies already subject to the NFRD
    2. Reporting in 2026 (on the FY 2025) for large companies that are not currently subject to the NFRD
    3. Reporting in 2027 (on the FY 2026* for listed SMEs (except micro undertakings), small and non-complex credit institutions and captive insurance undertakings
    4. Reporting in 2029 (on the FY 2028) for 3rd-country undertakings with net turnover above 150 M€ in the EU if they have at least one subsidiary or branch in the EU exceeding certain thresholds.

 

*Listed SMESs have a possibility to opt-out from the reporting requirement for a transitional period of 2 years

eolos contributors to this article

Baptiste Grüss

Consultant & Env. Policy Regulations Expert

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