Sustainability Advisory

CSRD reporting: What you need to know

insight featured image
The European Commission (EC) has issued the final regulation supplementing the Corporate Sustainability Reporting Directive (CSRD) regarding sustainability reporting standards to be followed in the European Union (EU).

The European Sustainability Reporting Standards (ESRS) apply to all companies within the scope of CSRD.

As the final text of the ESRS is now available, companies within their scope need to get ready now as some reporting entities within the scope of CSRD will have to apply ESRS for reporting periods commencing on or after 1 January 2024.

The following FAQs will help you understand a bit more about the CSRD and the ESRS that have been released.

What is the CSRD?

On 5 January 2023, the Corporate Sustainability Reporting Directive (CSRD) entered into force. It builds upon its predecessor the Non-Financial Reporting Directive (NFRD), which was issued in 2018. The CSRD expands the range of entities who will have to disclose sustainability information and introduces detailed reporting across a number of categories: preparation, strategy and business model, due diligence, governance, risk and opportunity management, and targets and metrics.

What is the objective of the CSRD?

The objective of the CSRD is to improve the existing requirements of the EU’s Non-Financial Reporting Directive (NFRD), to better harness the potential of the EU in the transition to a fully sustainable and inclusive economic and financial system, in accordance with the European Green Deal and the UN Sustainable Development Goals.

What is the timeline for CSRD?

Which entities will be in scope for CSRD?
  • Insurance and Banking firms
  • Companies listed on EU-regulated markets
  • “Large EU Companies (Listed and not Listed)"
  • EU companies that are a Parent of a “Large Group”
  • Small-medium sized EU undertakings
  • Subsidiaries and branches in the EU

The scoping criteria must meet at least two of the following:

  1. Total assets exceeding €20 million
  2. Net turnover exceeding €40 million
  3. 250+ employees.

Additional rules and scoping criteria apply for Group and EU Subsidiary entities of non-EU parents as defined within the CSRD.

What are the key consolidation considerations?
  • Parent undertakings of a large group need to report on a consolidated basis
  • Consolidated financial reporting is not the same as consolidated sustainability reporting
  • Entities need to provide an adequate understanding of the risk / impacts of the subsidiaries and disclose based on materiality which may go beyond control
  • Subsidiaries may be able to apply an exemption from preparing its own sustainability statements where the parent in the Group is consolidating across the structure
  • A temporarily available variant of the subsidiary exemption is available for certain EU subsidiaries with non-EU parents  

Consolidated sustainability reporting also applies to sustainability statements and goes beyond consolidation requirements covered within the financial statements with entities needing to provide an adequate understanding of the risk / impacts of the subsidiaries across any material topics.

What is the difference between NFRD and CSRD?

The most significant difference is the introduction of mandatory reporting standards under the CSRD in the form of the European Sustainability Reporting Standards (ESRS). Entities reporting under CSRD must apply these EU sustainability reporting standards and bring sustainability information into their annual management report, applying the same reporting period for both.

Which ESRS will apply to the first entities reporting under CSRD?

The EU Commission is at the final stages of approval of the first tranche or Set 1 of the ESRS. The last public consultation on the final amendments closed on 7 July 2023 and the final text was issued within the EU Delegated Acts on July 31 2023.

The first set of ESRS includes two 'cross cutting' and ten topical standards across the three ESG areas as outlined below:

What is the 'double materiality' principle?

The CSRD and ESRS introduce the concept of double materiality. Entities applying ESRS must report material impacts, risks and opportunities or 'IROs' across each topical area within their sustainability statements that are both financially impactful (outside in) and have an impact to people and the environment (inside out).

Double materiality concept: Summary overview and concepts 

What is the relevance of Stakeholders to the materiality assessment process?

Within ESRS, stakeholders are defined as both users of sustainability statements and other stakeholders or information users. Stakeholders are those who can affect, or be affected by, the organisation and both need to be incorporated into the due diligence process.

What phase-in reliefs have been provided?

A summary of phased-in Disclosure Requirements for all reporting entities is outlined below:

Year 1 Year 2 Year 3
Comparative information is not required.  
Datapoints related to their own workforce in ESRS S1 – social protection, persons with disabilities, work-related ill-health, and work-life balance are not required.
Financial effects related to non-climate environmental issues (pollution, water, biodiversity, and resource use) are not required, qualitative disclosures can be provided in the first three years.
In the absence of sector-specific standards, other available frameworks could be used to develop specific disclosures if required for material entity-specific sustainability matters not included in the first set of ESRS.
Company-specific disclosures that were developed prior to the ESRS being adopted can still be used.
There is a requirement to consider the value chain as part of the materiality assessment process but data gathering aspects are limited for the first three years and information on the value chain can be estimated or omitted if the information is not available during this time.

For reporting entities with less than 750 employees:

Year 1 Year 2 Year 3
Scope 3 Greenhouse Gas (GHG) emissions data, and ESRS S1 disclosures are not required.  
The disclosure requirements for biodiversity (ESRS E4), Workers in the value chain (ESRS S2), Affected Communities (ESRS S3) and Consumers and End-users (ESRS E4) are not required.  

In addition, until 2030, EU subsidiaries of non-EU parents can prepare just one report, which includes subsidiaries that would ordinarily be required to report separately, due to size or if they are listed. 

What's a reporting boundary and what needs to be considered?

CSRD expands the reporting boundary for undertakings beyond their own operations to include both upstream and downstream value chain activities. An undertaking must report material impacts, risks and opportunities within the value chain against ESRS disclosures or if other material impacts exist not covered by ESRS include entity specific disclosures. This applies to all tiers of the value chain.

Am I ready for CSRD implementation?

Depending on when you come into scope for CSRD and what your maturity level is with respect to your sustainability strategy, structures and reporting process,  you may have a number of areas to consider including:

We can help

We hope you find the information in this article helpful in beginning to understand the requirements of the CSRD. If you would like to discuss any of the points raised, please speak to your usual Grant Thornton contact or visit our CSRD page to find out more.

Subscribe to our mailing list

Receive the latest insights, news and more direct to your inbox.