CSRD — Corporate Sustainability Reporting Directive

The Corporate Sustainability Reporting Directive (CSRD) (Directive (EU) 2022/2464) is a fundamental reform of EU sustainability reporting, replacing the previous Non-Financial Reporting Directive (NFRD). It requires companies to disclose detailed and comparable information on environmental, social, and governance (ESG) matters under uniform European Sustainability Reporting Standards (ESRS).

The CSRD significantly expands the scope of companies subject to reporting obligations — from approximately 11,700 under the NFRD to an estimated 50,000 companies. It introduces the principle of double materiality: companies must report both how sustainability matters affect their business (financial materiality) and what impact they have on the environment and society (impact materiality).

A key element is the mandatory external assurance of sustainability reports, initially with limited assurance and prospectively with reasonable assurance. This is intended to strengthen confidence in the quality of sustainability information.

On 21 April 2021, the European Commission presented the proposal for the CSRD to replace the NFRD of 2014, which was deemed insufficient. After intensive negotiations, the European Parliament and the Council reached a provisional political agreement on 21 June 2022. The European Parliament adopted the directive on 10 November 2022, and the Council gave its final approval on 28 November 2022.

The CSRD was published in the Official Journal of the EU on 16 December 2022 and entered into force on 5 January 2023. Application is phased: large public-interest entities report from financial year 2024 (reports published in 2025). The Stop-the-Clock Directive (EU) 2025/794 postponed the deadlines for additional company groups by two years. In addition, the Omnibus I Directive (EU) 2026/470 (in force since 18 March 2026) substantially narrowed the scope: only companies with more than 1,000 employees AND more than EUR 450 million net turnover remain subject to reporting obligations, removing an estimated 80% of previously in-scope companies from the CSRD's scope of application.

The CSRD applies to companies established in the EU as well as certain third-country companies with significant operations in the EU. Application is phased:

• Wave 1 (financial year 2024): Large public-interest entities with over 500 employees that were already subject to the NFRD.
• Wave 2 (financial year 2027, after postponement): Large EU companies with over 1,000 employees and over EUR 450 million turnover (thresholds raised by Omnibus I).
• Wave 3 (financial year 2028, after postponement): Listed SMEs, small credit institutions, and captive insurance undertakings — under Omnibus I expected to be voluntary only.
• Wave 4 (financial year 2028): Third-country companies with over EUR 150 million EU turnover and at least one large EU subsidiary or EU branch.

• European Sustainability Reporting Standards (ESRS): Reporting according to uniform standards developed by EFRAG, covering environmental, social, and governance topics.
• Double materiality: Companies must assess both financial materiality (impact of sustainability matters on the company) and impact materiality (the company's impact on the environment and society).
• Digital tagging: Sustainability reports must be prepared in a machine-readable format (XHTML with inline XBRL tagging) to facilitate comparability and data access.
• External assurance: Mandatory assurance by an independent auditor, initially with limited assurance, and potentially with reasonable assurance from October 2028.
• Integration into the management report: Sustainability information must be disclosed in a dedicated section of the management report, not in a separate report.
• Value chain: Reporting on material sustainability matters along the entire value chain, including upstream and downstream activities.
• Taxonomy alignment: Disclosure of the share of turnover, capital expenditure, and operating expenditure aligned with the EU Taxonomy.

The last_amended field is set to 2025-04-14 (Stop-the-Clock Directive (EU) 2025/794). However, the entry itself references in history and key_dates the more recent Omnibus I Directive (EU) 2026/470, which entered into force on 18 March 2026 and substantively amended the CSRD. last_amended is therefore internally inconsistent.

key_dates: 2026-03-19 corrected to 2026-03-18