The new CSRD Directive broadens the obligation to report compared with requirements of the previous NFRD Directive and introduces new European Standards (European Sustainability Reporting Standards - ESRS) for harmonised reporting.

 

In addition to the companies already subject to the preparation of sustainability disclosure as required by the NFRD, the obligation now also extends to:

 

1. Significant public interest companies already subject to NFRD:

> Report in 2025 (on the financial year 2024)

 

2. Large unlisted companies which exceed at least two of the following criteria:

• Average number of employees: 250

• € 25 million balance sheet

• € 50 million in net turnover

> Report in 2026 (on the financial year 2025)

 

3. Small and medium listed enterprises (excluding microenterprises), small and non-complex credit institutions and captive insurance companies:

>Report in 2027 (on financial year 2026)

 

4. Enterprises and branches of subsidiaries with parent company outside the EU, where the parent company generated net turnover in the EU exceeding 150 million Euro for each of the past two consecutive financial years and at least:

• one subsidiary satisfies the size requirements set out in the CSRD and/or

• one branch has generated net turnover exceeding 40 million Euro for the previous fiscal year

>Report in 2029 (on financial year 2028)

 

Among the new requirements set out under the Corporate Sustainability Reporting Directive one of the major ones concerns the introduction of the new ESRS reporting standard (European Sustainability Reporting Standard) which becomes mandatory for all companies subject to  CSRD in order to guarantee greater harmonisation and comparability of sustainability reporting.

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IMPORTANT DISCLAIMER (upd. April, 2025):
EU Directive 2025/794 (“Stop the Clock”), published in the Official Journal of the European Union on April 16, 2025, incorporates certain elements of the simplification packages (“Omnibus Packages”) adopted by the European Commission in February 2025. Specifically, it amends the CSRD Directive by postponing the reporting obligations by two years for “Large undertakings” (reporting in 2028 for the 2027 financial year) and for listed SMEs (reporting in 2029 for the 2028 financial year). Member States have until December 31, 2025 to transpose these provisions into national law.