ESG Regulation in the EU: The Corporate Sustainability Reporting Directive (CSRD) and Its Impact

As environmental, social, and governance (ESG) considerations move from voluntary frameworks to regulatory mandates, the European Union has emerged as a global leader in sustainability-focused legislation. At the center of this transformation is the Corporate Sustainability Reporting Directive (CSRD)—a landmark regulation reshaping how companies report on their ESG performance and risk.

What Is the CSRD?

The CSRD is the EU’s latest and most ambitious legislative step toward increasing corporate transparency on sustainability. Officially adopted in November 2022, the CSRD replaces and significantly expands the scope of the Non-Financial Reporting Directive (NFRD). The CSRD entered into force on January 5, 2023, and member states must transpose it into national law by July 6, 2024.

The directive aims to ensure that companies across Europe—and those doing business in the EU—report consistent, comparable, and reliable ESG data. This information is meant to support investors, policymakers, and the broader public in making informed decisions that drive sustainable outcomes.

Key Elements of the CSRD

  1. Expanded Scope:
    • The CSRD will apply to nearly 50,000 companies, up from 11,700 under the NFRD.
    • It includes:
      • All large EU companies (meeting two of three: €40M turnover, €20M assets, 250+ employees)
      • Listed SMEs (with a transitional phase)
      • Non-EU companies with significant activity in the EU (over €150M in EU turnover)
  2. Mandatory ESG Reporting:
    • Companies must report on environmental, social, and governance issues, focusing on double materiality—how sustainability issues impact the company, and how the company impacts people and the planet.
    • Reports must align with European Sustainability Reporting Standards (ESRS) developed by the EFRAG (European Financial Reporting Advisory Group).
  3. Assurance Requirements:
    • Sustainability information must be audited with at least limited assurance, raising the bar on data reliability.
  4. Digital Format:
    • Reports must be machine-readable using the European Single Electronic Format (ESEF) for better accessibility and transparency.

Implementation Timeline

The CSRD introduces a phased reporting approach based on company size and type:

YearWho Must Report
2025 (FY 2024)Companies already subject to the NFRD
2026 (FY 2025)Large companies not previously under NFRD
2027 (FY 2026)Listed SMEs (except micro-enterprises)
2029 (FY 2028)Non-EU companies with significant EU activity

European Sustainability Reporting Standards (ESRS)

The ESRS define the format and content of sustainability disclosures. As of July 2023, the EU adopted the first set of 12 sector-agnostic standards covering:

  • Environment: Climate change, pollution, water & marine resources, biodiversity, and resource use
  • Social: Workforce, workers in the value chain, affected communities, and consumers
  • Governance: Business conduct, anti-corruption, and risk management

Future sets will include sector-specific standards, tailored for industries like energy, agriculture, and financial services.

Real-World Examples: How Companies Are Preparing

  • Volkswagen Group has integrated sustainability reporting into its financial disclosures, aligning with the EU Taxonomy and pilot ESRS.
  • SAP, a German software company, has begun CSRD-aligned scenario analyses and expanded its data governance team.
  • Unilever has mapped its reporting against both the CSRD and global frameworks like the GRI and TCFD to streamline compliance and investor communication.

These companies are building robust ESG data pipelines, aligning internal systems with ESRS metrics, and training finance and sustainability teams on the evolving standards.

Strategic Implications for Businesses

Preparing for CSRD compliance isn’t just about avoiding regulatory penalties—it’s a strategic move. Companies that embed ESG reporting into their operations can unlock:

  • Enhanced investor confidence through credible, comparable disclosures
  • Operational efficiencies from better risk and performance management
  • Improved stakeholder trust from transparent sustainability commitments

However, failing to prepare for CSRD could result in reputational damage, legal risks, and restricted access to capital.

How to Prepare for CSRD Compliance

  1. Conduct a Double Materiality Assessment:
    • Identify sustainability risks and impacts on both business and society.
  2. Establish Governance Structures:
    • Involve the board, internal audit, and cross-functional ESG teams.
  3. Upgrade Data Management Systems:
    • Implement digital tools for data collection, verification, and reporting.
  4. Engage External Assurance Providers:
    • Begin trial audits to assess readiness.
  5. Align with Global Frameworks:
    • Coordinate CSRD preparation with GRI, SASB, and TCFD where applicable.

Final Thoughts

The CSRD is a pivotal regulation that is transforming how businesses think about transparency, risk, and long-term value. While compliance may seem daunting, the regulation offers an opportunity to future-proof operations, build stakeholder trust, and demonstrate leadership in sustainability.

The companies that act now to integrate ESG into their reporting DNA will not only comply with the CSRD—they will help shape the future of responsible business in Europe and beyond.

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