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New: voluntary, comparable reporting in the context of the VSME
Companies without reporting obligations can take advantage of the voluntary reporting standard for small and medium enterprises (VSME). This standard has a significantly smaller scope than the ESRS and does not require a double materiality assessment. Companies that are subject to reporting obligations can request data points from non-reporting companies in accordance with the VSME – to map their own supply chain, for example.
With the CSRD (the Corporate Sustainability Reporting Directive) the EU is breaking new ground in corporate reporting. In addition to financial information, the disclosure of non-financial data in annual reports is now mandatory. This means that both aspects will gradually be given equal importance, including through a review by auditors.
The new directive is intended to lead to transparency and comparability of companies’ ESG (environmental, social and governance) performance. It also aims to guide companies on their journey towards a decarbonised economy, highlighting opportunities for action and creating competitive advantage for actions already taken.
In February 2025, the European Commission presented substantial proposals for changing the number of reporting companies as well as the reporting framework.
The Corporate Sustainability Reporting Directive (CSRD) is an EU directive on sustainability reporting that has been in force since January 2023. It replaces the previous directive, the Non-Financial Reporting Directive (NFRD), and requires significantly more companies to disclose their ESG data. Now, the omnibus package issued in late February 2025 proposes a redefinition of the user group, with around 10,000 companies likely to be affected by the CSRD. The final decision is due in the second quarter of 2025. Originally, 50,000 companies were to have been subject to CSRD reporting.
The new directive is accompanied by a prescribed reporting methodology – the European Sustainability Reporting Standards (ESRS). These have been developed by the European Financial Reporting Advisory Group (EFRAG) and are mandatory for all reporting companies.
The ESRS currently comprise twelve standards. The standards are divided into general standards and topical standards. The standards will be expanded to include sector standards in the coming years.
In addition to data disclosure, ESG-related actions, objectives and strategies are an important aspect of the ESRS. This is intended to drive the transformation towards a sustainable economy.
A very important element of the new reporting scheme is the double materiality assessment, which must be applied to each company at the beginning of the process. This assessment determines the specific content of the environmental, social and governance report.
The double materiality assessment requires companies to apply two perspectives:
The CSRD sets out the scope of reporting. Reporting obligations depend, among other things, on the size of the company. Now, under the omnibus package, only companies with over 1,000 employees and more than either EUR 50 million in revenue or EUR 25 million balance sheet total will be directly affected by the CSRD, and only starting in 2028 with reporting on the 2027 financial year. (Prior to this omnibus package and up until now, companies were included if they exceeded two out of three criteria – 250 employees, EUR 50 million revenue, EUR 25 million balance sheet total – or if the company was a listed SME).
As a climate protection organisation with 20 years of experience behind us, we have long been supporting companies with the Science-Based Targets Initiative (SBTi), reduction paths, carbon footprinting and climate strategy. These issues also form an important part of the ESRS in area E1 Climate Change. Specifically, we offer the following services to help you meet your CSRD obligations:
Need help implementing the CSRD? Contact us to arrange a no-obligation initial meeting.
This product is part of the climate strategy. All calculations of CO2 emissions are carried out with the myclimate EcoCloud carbon management platform.