The Corporate Sustainability Reporting Directive (CSRD) updates the non-financial reporting requirements set out in the Non-Financial Reporting Directive (Directive 2014/95/EU, the NFRD). It is a far-reaching update, which will have a major impact on the way companies address corporate sustainability issues.
Some key issues
CoverageThe CSRD expands the number of companies required to report on their sustainability from 11,000 to more than 50,000 companies and significantly increases the amount of information that companies will be required to report.
Sustainability reporting standards (ESRS)The European Commission has been empowered to adopt sustainability reporting standards. These standards are known as the European Sustainability Reporting Standards (ESRS). In December 2023 the European Commission adopted the Delegated Act on the first set of ESRS.
Audit of reportsAnother important new feature of the CSRD is that it establishes audit requirements for sustainability reporting, with the aim of ensuring the reliability of data and avoiding greenwashing and double counting.
Double materialityThe following is an example: companies are obliged to report both on the impact of their activities on people and the environment, and on how sustainability issues affect them. This is known as the dual materiality perspective, in which risks to the company and the impact of the company represent
a materiality perspective. Companies should consider each materiality perspective in its own right, and disclose information that is meaningful from both perspectives and information that is meaningful from only one perspective.
Digitisation: companies will be required to prepare their sustainability reports in XHTML format in accordance with the Single European Electronic Format (ESEF) Regulation and to "tag" the reported sustainability information according to a digital categorisation system. The aim of the digitisation is that the information
on sustainability can be easily incorporated into the single European access point, as foreseen in the Capital Markets Union Plan.
Which companies are affected and what is the timetable?
National transposition:
Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with Articles 1 to 3 of the Directive by 6 July 2024 at the latest.
Timetable for implementation:
1 January 2024 (reporting in 2025): companies with more than 500 employees already subject to the NFRD.
1 January 2025 (reporting in 2026): large companies that are not in the scope of the NFRD and that meet at least two of the three criteria:
+250 employee
+20 M € of total assets
+40 M € turnover
1 January 2026 (reporting in 2027): listed SMEs, small and non-complex credit institutions and captive insurance companies. Reporting in 2027.
How can unlisted SMEs adapt?
While they are not obliged to report, unlisted SMEs can voluntarily use the NEIS. As many SMEs increasingly receive requests for sustainability information (e.g. from banks that lend money or large companies to which they supply), collecting and disclosing sustainability information could become common business practice for all companies. Using European standards would make it easier for SMEs to communicate the necessary information to investors, lenders, customers and other stakeholders.
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