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Corporate Sustainability Reporting Directive
Directive (EU) 2022/2464 mandating detailed sustainability reporting (ESG) by EU large undertakings and listed SMEs, replacing the NFRD. Reporting follows the European Sustainability Reporting Standards (ESRS), is audited (limited then reasonable assurance), and published in iXBRL format. Phased application from 2025 fiscal year reporting through 2028. The 2025 Omnibus package adjusts thresholds and timeline. Has extraterritorial effect on non-EU groups with significant EU revenue.
The CSRD (Corporate Sustainability Reporting Directive — Directive 2022/2464 of 14 December 2022) requires large undertakings and listed SMEs in the European Union to publish a detailed sustainability report, audited and integrated into the management report. It progressively replaces the NFRD (Non-Financial Reporting Directive) of 2014, considered too limited and not comparable.
The content of the report is defined by the ESRS (European Sustainability Reporting Standards), developed by EFRAG and adopted by delegated regulation of the Commission. The ESRS cover ten topics: climate change (E1), pollution (E2), water (E3), biodiversity (E4), circular economy (E5), own workforce (S1), value chain workers (S2), affected communities (S3), consumers (S4), business conduct (G1).
Application is phased: fiscal year 2024 (report published in 2025) for large undertakings already subject to the NFRD, fiscal year 2025 for other large undertakings (>250 employees or >€40M revenue or >€20M balance sheet), fiscal year 2026 for listed SMEs (with a simplified regime), fiscal year 2028 for EU subsidiaries of non-EU groups with more than €150M revenue in the EU.
The report is mandatorily audited, first with limited assurance, then reasonable assurance from 2028. The publication format is XBRL/iXBRL (digital tagging), aligned with ESEF.
European extra-financial reporting began with the NFRD (Directive 2014/95), which required listed companies with more than 500 employees to publish a non-financial performance statement. The track record showed reports that were too heterogeneous, not comparable, and of variable data quality.
The CSRD emerged from a desire to tighten requirements, linked to the European Green Deal of 2019 and the sustainable finance action plan. The Commission's proposal was filed in April 2021, adopted in November 2022, published on 14 December 2022 in the OJEU.
The ESRS were adopted by delegated regulation (EU) 2023/2772 of 31 July 2023, published on 22 December 2023. In February 2025, the Commission announced an "Omnibus" package adjusting the CSRD timeline and thresholds to reduce the administrative burden, notably by postponing certain waves. The detailed arbitrations are being adopted.
In France, the CSRD is transposed by Ordinance No. 2023-1142 of 6 December 2023.
For an executive, the CSRD is not a communication topic but a transformation project. The sustainability report must be auditable, which implies traceable data, internal controls, and formalized processes. Many finance departments discover in 2025 that they do not have the data needed to answer the ESRS — which means setting up collection from sites, suppliers, and subsidiaries.
The initial effort for a large undertaking is measured in hundreds of person-days over 12 to 18 months. The recurring cost afterwards (annual collection, audit, maintenance) remains significant. But the value of the report goes beyond compliance: it becomes an internal steering asset (carbon, social, governance) and a factor for access to sustainable finance.
The risk for executives: a first report that is not auditable or not published on time exposes the company to sanctions and a strong negative signal to investors and clients.
On the CSRD, we work in complement to ESG consulting firms and statutory auditors: our contribution is on the data chain. We design and implement the pipelines that collect, aggregate, validate, and expose ESRS indicators within the client's systems (ERP, HR, procurement, energy, real estate).
Concretely: mapping of ESRS indicators and their sources, connectors to SAP / Oracle / Workday / CMMS / energy IoT, automated consistency and quality controls, end-to-end traceability required by the audit, and a living dashboard to steer over 12 months (not just publish in March of year N+1).
For cross-cutting topics (scope 3 carbon, social indicators, supply chain due diligence), we tool up with AI building blocks when useful and explainable, never as a black box. Our principle: a CSRD report steered in year 1, auditable in year 2.
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Free initial scoping. We assess your context and identify concrete levers.