The European Union’s Corporate Sustainability Reporting Directive (CSRD) is top of mind for many of our sustainability clients, with the first reporting deadline coming up in July 2025 (covering 2024 data).
Many companies are unsure, however, about what CSRD means for them and how to prepare. Over the coming months, we’ll help cut through that confusion with a series of posts on this blog and with a virtual event on October 15. We’ll discuss insights into how regulatory developments are changing sustainability communications, strategies for using the new reports to build long-term brand value, and tips on what companies can do now. Please follow LEFF on LinkedIn for more information, including the big reveal of our three exciting panelists. (Spoiler: I’m one of them.)
This first blog post will cover the basics of CSRD: what it is, what problem it addresses, and who needs to care. Our goal is to provide readers with not only a good grounding in these topics but also resources for those who want to dig a bit deeper.
What problem is CSRD aiming to solve?
Over the past decade, policymakers, consumers, employees, and investors have begun asking for more information on environmental, social, and governance (ESG) issues. As a result, the number of ESG reporting standards and frameworks have expanded greatly. (See here for a useful summary of existing rules and guidelines.) Most of these have been optional, however, and varying requirements and metrics have limited the ability to compare across companies and sectors.
Enter CSRD, a new standard for how companies disclose ESG information. CSRD establishes a shared framework for reporting nonfinancial data and integrating financial and nonfinancial disclosures. Detailed, standardized reports will provide greater transparency to all stakeholders. But the overall intent of CSRD is much bigger. The idea is that the metrics and targets that companies now need to report will end up accelerating the transformation of the business environment, increasing resilience and sustainability. And there’s data to support this theory of change: A growing body of research finds that transparent companies tend to perform better—and are rewarded by investors accordingly.
What do companies need to disclose, and which bits are new?
Disclosures made under CSRD must align with the European Sustainable Reporting Standards (ESRS), published by EFRAG. Together, the 12 ESRS cover the full suite of ESG-related topics (Exhibit 1).
Exhibit 1 – What topics are covered by CSRD and the ESRS?
Source: Greenscope, “Final version of the ESRS,” August 2023.
CSRD expands upon and replaces the European Union’s Non-Financial Reporting Directive. CSRD goes further than any previous mandatory reporting framework in a number of ways, four of which are particularly important:
- Scope 3 emissions: For the first time, many companies will be required to disclose their Scope 3 emissions, which are emissions produced in the company’s value chain. PwC has a good explainer.
- Double materiality: Many companies are already familiar with financial materiality, which looks at how climate and sustainability factors may affect a company’s financial performance. CSRD adds the idea of impact materiality, which looks at how a company’s activities may affect society and the environment. Deloitte offers a step-by-step guide to conducting a double materiality assessment.
- Data integration: A core goal of CSRD is to integrate financial and ESG information rather than the two being considered as separate silos. To that end, all CSRD-related information will need to be provided within a company’s annual or management report.
- Assurance: To verify their accuracy, all reports must be audited by a third party before publication.
Who needs to care?
The CSRD requirements introduce mandatory sustainability disclosures for large and listed companies with a significant presence in the European Union. In total, this will likely be nearly 50,000 companies, though not all will have to report immediately (see page 12 of the European Union’s CSRD FAQ document for more information).
The impact of CSRD, however, will likely be felt beyond those companies immediately affected. The European Union has a long history of exporting its standards, and the CSRD will likely be the first in a series of corporate disclosure directives that mandate the integration of financial and ESG information.
What form will disclosures take?
Companies will be expected to provide all CSRD-related information in either their annual report or their management report. A chunky appendix of data tables won’t be enough; ESRS 1 specifies that companies must provide narrative disclosures to explain the relationships among sustainability, financial, and risk information. There are technical requirements, too, with all sustainability information to be provided in xHTML format in line with European Single Electronic Format regulations.
These requirements will likely further limit the number of companies that have the capacity and expertise to produce their ESG reports in-house, and the LEFF Sustainability Group has already seen an increase in requests for support. We’re really enjoying diving into these projects and are excited by the opportunities these new reports offer to tell our clients’ sustainability stories in compelling, data-driven ways.
CSRD ushers in a new era of sustainability reporting, and the array of data needed to satisfy the new requirements means companies urgently need to have their reporting plan in place. The stakes are high, and we understand that many involved in the reporting process are feeling anxious about what’s ahead. However, the new regulations do also offer huge opportunities to build stakeholder trust and business value. The next blog post in this series—and our upcoming virtual event—will look in more detail at some of the opportunities and challenges that come with CSRD and how companies can navigate them.
Ready to learn more about the impact of CSRD on sustainability communications? Register for our virtual event below.