CSRD and corporate sustainability: a comprehensive overview

• All listed companies on the EU regulated market (including listed SMEs, but no micro-enterprises) ​

• All large companies exceeding two of the three following criteria*:  ​

  • > 250 employees and/or ​

  • > €40M Turnover and/or ​

  • > €20M Total Assets ​

• Third-country undertakings with net turnover above 150 million in the EU if they have at least one subsidiary or branch in the EU exceeding certain thresholds.​

*If the company is a subsidiary of a larger group, it is exempted from the obligations if the parent company produces a consolidated sustainability report that conforms with the directive.​

Under the CSRD, a company will need to include in a dedicated section of its annual report (not in separate sustainability reports) the information necessary to understand the company’s impacts on sustainability matters as well as how sustainability matters affect the company’s own development, performance and position.

The information that a company is required to provide must include information about the company’s own operations and about its value chain.

Companies under scope will need to seek limited assurance of the sustainability information disclosed.

The CSRD amends the existing Non-Financial Reporting Directive (NFRD) and substantially increases reporting requirements. Additionally it applies to a drastically larger scope of companies (approx. 50.000 companies in the EU) across all sectors. ​

The specific disclosure requirement are detailed by the European Sustainability Reporting Standards (ESRS) to ensure that companies have clear standards to report in a consistent and comparable manner. 

At this point, the following draft ESRS standards are available:

• The cross-cutting standards set out general requirements that will apply across all of the topics covered by the CSRD as well as a series of mandatory general disclosures (eg related to materiality)

• The sectors agnostic standards cover a set of ESG topics can be relevant for any company, independent of the sector. For each ESG topic, these standards include disclosure requirements related to materiality, policies and actions, metrics and targets and financial effects.

The final adoption of these standards is expected for June 2023. As these standards have already been reviewed and amended we assume that the draft standards  available will largely correspond to the standards adopted.

Sector-specific standards will later supplement these draft standards.

NFRD-compliant companies already have to be compliant with the CSRD from the 1st of January 2024 onwards and all other large companies in 2025. Therefore, we advise companies to start preparing as soon as possible.

A first step is to launch a double materiality process, that will determine what ESG related topics are material to the company. This step is mandatory for all companies under scope and will form the basis for the other CSRD requirements to respect.

Additionally a CSRD gap analysis would allow companies to have a better understanding to what extent the information available and the processes in place already meet certain requirements, and where action is required in order to make sure the company is prepared.