Corporate Sustainability Reporting Standard (CSRD)
What is CSRD?
The Corporate Sustainability Reporting Directive (CSRD) aims to raise sustainability reporting to the same level as financial reporting. Companies that report on sustainability on the basis of the CSRD must in future disclose uniform EU standards for sustainability information, so-called European Sustainability Reporting Standards (ESRS).
What does CSRD mean for businesses?
With the new CSRD, the number of reporting organisations in the EU will increase by a factor of 4 to around 49,000 companies. More than 15,000 German companies will gradually have to report on their sustainability performance in accordance with the European Sustainability Reporting Standards (ESRS) from 2025. The expansion of the affected groups and clear EU-wide regulations regarding formats, contents, key figures, deadlines and audit obligations are intended to increase transparency with regard to sustainability-related performance in the economy.
Facts and figures on CSRD
The new European Sustainability Reporting Directive (CSRD) came into force on 05.01.2023 and is to be implemented in the national law of the EU member states within 18 months (by mid-2024 at the latest).
In Germany, the transposition into national law is expected in late autumn 2023. The CSR Directive Implementation Act (CSR-RUG) currently in force in Germany on the disclosure of information on non-financial aspects is thus expected to be replaced from 2024 - at least with regard to environmental, employee and social concerns, respect for human rights and combating corruption and bribery (section 289c HGB).
The Sustainability Board of the European Financial Reporting Advisory Group (EFRAG), as the publisher of the indicators, defined the concrete contents and indicators for reporting. In accordance with the CSRD, these are divided into twelve cross-sectoral standards (European Sustainability Reporting Standards - ESRS). The indicators are now also available in German and can be accessed on the website of the European Commission.
The final version of the delegated act on the first set of these standards was adopted by the European Commission on 31 July 2023. Confirmation by the European Parliament and the European Council is still pending. If no objections are raised by the end of the year, the ESRS will be mandatory for companies subject to CSRD reporting requirements from the 2024 financial year onwards. We will inform you regularly about the latest developments.
CSRD - who is affected and what are the report contents?
The CSR reporting obligation will be extended as follows:
From 1 January 2024
Companies with more than 500 employees that are already required to report under the EU's Non-Financial Reporting Directive (NFRD).
From 1 January 2025
All large companies (listed or unlisted) that meet two of the following three criteria:
- more than 250 employees
- more than 40 million euros turnover
- more than 20 million euros in total assets
From 1 January 2026
Listed SMEs, small and non-complex credit institutions and captive insurance and reinsurance undertakings.
From 1 January 2028
Also non-EU companies that have an annual net turnover of more than €150 million in the EU and have at least one subsidiary or branch in the EU
For all the above deadlines, the de facto publication of the report is one year later. There is always a reporting obligation for the previous business year, the corresponding information must be disclosed by 30 April of the following year. This means that, for example, large companies that have only published their non-financial indicators voluntarily up to now, will have to report on the 2025 business year in 2026.
Set 1 applies to non-SMEs and has the following structure:
The cross-sectional standards ESRS1 and ESRS2 define the general requirements for a sustainability report, while the topic-specific standards describe reporting requirements of the central sustainability topics.
According to the amendments of the EU Commission, the standard ESRS 2 ("General Disclosures") is mandatory for all companies. Other information only has to be disclosed if it has been assessed as relevant for the business model and the company's activities after conducting the materiality analysis. This should enable companies to save costs, as the reporting of non-relevant information can be dispensed with. If the materiality analysis shows that the topic of climate change is not material and therefore reporting according to ESRS E1 ("Climate Change") is waived, this decision must be explained in detail.
In the final version of the ESRS, disclosure requirements for the first years of reporting were defined in Annex C of Annex 1: Some standards (cross-sectoral and thematic) can be omitted in the first years or only presented qualitatively.
Companies with less than 750 employees may omit disclosures on certain topics in the first two years of application. These include, among others, scope 3 greenhouse gas emissions, information on own employees and on biodiversity.
In the first reporting year, all companies can waive information on the expected financial effects of environmental risks and individual information on their own employees. In addition, the EU Commission grants further freedom with regard to information on biodiversity and other social issues.
A list of the indicators and the gradual introduction of the disclosures can be found here.
According to the CSRD, the verification of sustainability reporting is mandatory. One of the main points of contention was the approval of institutions for auditing the company information: May only auditors audit or also certification bodies and environmental auditors?
In the final version, this decision was delegated to the states. How the state law will be implemented in Germany is still open. Consultations at the state level are already in full swing and, at least from Brussels, no exclusion has been specified so far. We therefore hope to be able to support our clients in the audit of information subject to CSRD in the future! A decision on the audit authority is expected in the fourth quarter of 2023. We will inform you promptly.
To accompany the publication of the final version of the standards, the European Commission provides a FAQ.
With the publication of the final ESRS, EFRAG has taken on the task of supporting entities in their application and has developed initial guidance:
The published documents are working papers discussed during the public meeting of the Sustainability Reporting Board (EFRAG SRB) on 23.08.2023. Once approved by the SRB and the EFRAG Sustainability Reporting Expert Group (SR TEG), the draft guidelines will be made available for public comment, then reviewed again and, once approved, finally published as non-binding technical guidance on the application of the ESRS.
CSRD - what to do? Recommendations by GUTcert
If your company has to report on the non-financial indicators in terms of the CSRD in the coming years, the bridging period should be used: Collect and analyse the necessary data promptly so that a solid sustainability strategy can be defined and missing key figures can be collected.
We will be happy to support you with our SustainabilityCheck in order to record the current status of your sustainability performance.
Have you already written a sustainability report? Then have any existing gaps to the new standards checked.
If your company already operates management systems, you have a clear advantage: you benefit from many interfaces between sustainability reporting and your certifications.
Training courses at the GUTcert Academy
We have been supporting our clients in writing sustainability reports for many years: We review them and conduct workshops to make the definition of the essential topics of sustainable development transparent. For this purpose, we offer numerous training courses for those responsible.