Corporate Sustainability Reporting Directive
European directive requiring large companies to report sustainability information under the ESRS standards, with limited external assurance. Directive (EU) 2022/2464 published in the OJEU on 16 December 2022.
Context
CSRD (Corporate Sustainability Reporting Directive) is the European directive that requires companies to report sustainability information in a structured, auditable and comparable manner. It amends the Accounting Directive 2013/34/EU by introducing the sustainability statement integrated into the management report.
Regulatory origin
Directive (EU) 2022/2464 of the European Parliament and of the Council, published in OJEU L 322 on 16 Dec 2022. It amends Directive 2013/34/EU (Accounting Directive) and other related rules.
Progressive application in 4 waves
Large companies and listed entities with more than 500 employees (previously subject to NFRD).
Other large companies (more than 250 employees or more than EUR 40M turnover).
Listed SMEs (with opt-out until 2028).
Non-EU companies with significant activity in the EU market.
What the sustainability statement reports
Double materiality (impact + financial · ESRS 1 §3 + IRO-1 + SBM-3).
Topical disclosures E1-E5 + S1-S4 + G1 according to materiality.
XBRL tagging in accordance with the ESRS taxonomy published by EFRAG.
Integrated into the management report · limited external assurance (scalable to reasonable).
Timeline
CSRD adopted
Directive (EU) 2022/2464 approved · published in OJEU L 322.
Wave 1 application
Large companies and listed entities with more than 500 employees.
Omnibus I published
Directive (EU) 2026/470 simplifies thresholds and postpones the timetable.
Post-Omnibus application
Companies with more than 1,000 employees AND more than EUR 450M.
Revised ESRS
EFRAG delivers revised ESRS with radical simplification.
Applied case
A textile brand assesses its CSRD exposure post-Omnibus to plan its first sustainability statement.
Pre-Omnibus: the brand was a Wave 2 candidate (2025) with first application 2026.
Post-Omnibus: the brand falls OUTSIDE the mandatory CSRD (it does not meet the DOUBLE threshold of 1,000 employees AND EUR 450M).
Strategic decision: adopt VSME (Recommendation C(2025)4984) as simplified voluntary reporting to respond to large B2B customers that ARE obliged.
Benefit: reduces reporting cost (EUR 15-25k VSME vs EUR 100k+ full CSRD) while maintaining ESG positioning in the value chain.
Common mistakes
The CSRD is not the renewed version of the NFRD: it replaces it within the framework of the Accounting Directive.
The NFRD (Directive 2014/95/EU) introduced into the Accounting Directive 2013/34/EU the former Arts. 19a and 29a on non-financial information for public-interest entities with more than 500 employees (recital 17 CSRD). The CSRD replaces those articles with a reinforced sustainability information obligation subject to ESRS and assurance, with an expanded universe and a staggered timetable in Art. 5.2.
The CSRD is not a regulation: it is a directive and requires transposition.
The CSRD is a directive with a transposition deadline set at 6 July 2024 for Arts. 1 to 3 (Art. 5.1). Art. 4 is directly applicable ("Article 4 shall be binding in its entirety and directly applicable in all Member States", Art. 8). The technical implementing rules (ESRS) are in a delegated regulation: Commission Delegated Regulation (EU) 2023/2772.
Not being obliged by the CSRD does not mean being free of its effect.
The amended Art. 19a.3 of Directive 2013/34/EU extends the information obligation to own operations and the value chain; recitals 33 and 53 detail the value chain information that obliged companies must request from their suppliers. An SME that is not obliged may receive indirect informational pressure from its covered European customers.
The 2025 Omnibus package has not yet reduced the CSRD universe to companies with more than 1,000 employees.
That is the Commission proposal of 26 February 2025 ("Omnibus Simplification Package", recital 3 of Delegated Reg. 2025/1416), pending legislative processing at the close of this term. What is law in force is Directive (EU) 2025/794 "stop-the-clock" (in force 17 April 2025) and Delegated Reg. (EU) 2025/1416, of 11 July 2025, which amends Annex I, Appendix C, of ESRS 1 for entities with up to 750 employees.
Frequently asked questions
What is the CSRD?
Directive (EU) 2022/2464 Corporate Sustainability Reporting Directive, amends the Accounting Directive 2013/34/EU to introduce an obligation to report sustainability under binding European standards (ESRS). It replaces the NFRD by expanding the applicable universe and the informational depth.
To which companies does the CSRD apply?
Progressive application: (i) large public-interest companies with >500 employees from 2024 (2025 report), (ii) large companies that meet 2/3 criteria (>250 employees, >EUR 50M turnover, >EUR 25M balance sheet) from 2025 (2026 report), (iii) listed SMEs from 2026 (2027 report with opt-out until 2028). Stop-the-Clock Directive (EU) 2025/794 delayed application for waves 2 and 3.
How is the CSRD complied with?
Through a sustainability statement integrated into the audited annual management report, drafted in accordance with the ESRS Set 1 standards (Commission Delegated Regulation EU 2023/2772). It requires double materiality, mandatory datapoints + datapoints subject to materiality, XBRL tagging and limited verification by an auditor (with escalation to reasonable verification from 2028).
What is the difference between the CSRD and the CSDDD?
The CSRD requires reporting sustainability information under ESRS. The CSDDD (Dir. EU 2024/1760) requires applying due diligence on human rights and the environment in the chain of activities. They are complementary regimes: the CSRD is disclosure (what I report), the CSDDD is behaviour (what I do). A company may be subject to one, the other or both.
What is the difference between the CSRD and the former NFRD?
The NFRD (Dir. 2014/95/EU) applied to ~12,000 companies with lax criteria and without a common standard. The CSRD applies to ~50,000 companies, introduces the ESRS as a binding standard with specific datapoints, requires external verification and a digital XBRL format. A qualitative leap in scope and rigour.
What penalty is there for breaching the CSRD?
The penalties are set by the Member States during transposition. In Spain, transposition via Royal Decree-Law 6/2023 establishes fines of up to EUR 1,200,000 + possible exclusion from public tenders + personal liability of directors. Material omission or falsity may trigger criminal action for a corporate offence.
Fuentes oficiales
- European Parliament and Council · OJEU L 322, 16 Dec 202214 dic 2022Directive — legislation in force
- Commission Delegated Regulation (EU) 2023/2772 — ESRS Set 1 (12 cross-cutting and topical standards)European Commission · OJEU L, 22 Dec 202326 jun 2013 (modificada 2022)Delegated regulation — Set 1 standards
- European Parliament and Council · OJEU Series L, 26 Feb 202611 jul 2025Amending directive — threshold reform
- European Financial Reporting Advisory Group · EFRAG7 ago 2024Technical implementation guidance
