April 2, 2025
The Corporate Sustainability Reporting Directive (‘CSRD’) is the new EU sustainability reporting framework for non-financial undertakings. It serves as a replacement of the Non-Financial Reporting Directive (‘NFRD’), expanding its scope of application and introducing new reporting requirements.
For an overview of the most relevant changes, check this article.
The CSRD only requires companies that fulfil any of the following criteria to report on sustainability:
Companies established under public law are excluded, although they can still report voluntarily.
The European Commission adopted the CSRD in late 2022. The Directive entered into force in January 2023. The rules will start applying:
Nevertheless, many EU Member States have failed to transpose the CSRD on time. The EC has brought infringement procedures against 17 Member States: Belgium, Czech Republic, Germany, Estonia, Greece, Spain, Cyprus, Latvia, Luxembourg, Malta, TheNetherlands, Austria, Poland, Portugal, Romania, Slovenia and Finland.
The lack of transposition does not waive the obligations imposed by the CSRD, but it does create legal uncertainty. In their transposition, Member States can adjust the scope of application of the CSRD, create exemptions, rules for groups of companies and other special cases and determine the sanctions in case of non-compliance, among other rules left to their discretion.
The CSRD focuses on how an organisation manages its resources, treats its employees, engages with local communities and minimises its environmental footprint.
Undertakings must disclose how sustainability affects their value (financial materiality), as well as how the performance of their activities and the way they manage their business impact sustainability factors (impact materiality). They must report on both types of impacts and the interrelation between them. This exercise is known as the ‘double materiality’ assessment.
Such assessment goes beyond purely sustainability factors. It predicts how the business model, corporate strategy, organisational structure and operations of the company will behave in a changing climate or social background. The information assessed includes aspects related to human resources, the value chain, the capital of the company, etc. The information is of both qualitative and quantitative nature and covers short, medium and long-term impact scenarios.
To measure these impacts, undertakings must monitor a variety of indicators. To mention a few:
These indicators are measured with reference to the European Sustainability Reporting Standards (‘ESRS’), which specify the information to be disclosed. The ESRS include cross-cutting standards and topical standards on ESG matters, which apply to all sectors; and sector specific standards, which vary considering the business activity and its particular measurable impacts.
For more information on the ESRS, check this article.
The Sustainability Report provides key information on an entity's sustainability practices, as well as its achievements, challenges and future commitments. The key points to take account of are:
Complying with the CSRD can be a challenging task due to its novelty, complexity and correlation with other reporting requirements. The CSRD expanded the scope of application of non-financial reporting requirements and introduced stricter standards compared to previous regulations.
In defence of this directive, it solves an increasingly visible problem in ESG reporting:the lack of unified standards. Even though existing international standards were voluntary, their value for investors and shareholders was significant enough to achieve a high level of observance. Nevertheless, the fact that each company responds to a different framework made them impossible to compare. Investors were unable to make well-founded and informed decisions without harmonising the methodology used for measuring each company’s sustainability indicators.
Admittedly, the new framework is still very novel, which means that it will probably undergo several amendments to improve its practical application where experience points out its flaws. In a few reporting periods, common approaches to sustainability reporting will become apparent and all players will benefit from the standardisation outlined above. To better understand the benefits of standardisation, check this article.
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