- The CSRD does not require "a carbon footprint", but the ESRS E1 climate standard requires you to publish your scopes 1, 2 and 3 emissions: the footprint is the practical condition.
- Since the Omnibus (December 16, 2025), the CSRD targets companies with more than 1,000 employees AND more than €450M in net turnover (cumulative criteria), around 80% fewer companies.
- Below the threshold, the voluntary VSME standard takes over; and your customers subject to the CSRD will keep asking you for carbon data for their scope 3.
- A well-built footprint directly feeds ESRS E1, but also your EcoVadis and CDP assessments.
Is a carbon footprint mandatory for the CSRD?
Not as such. The CSRD does not require "a carbon footprint", it requires sustainability information, including a climate section. That section is the ESRS E1 standard, which applies if climate change emerges as material from your double materiality analysis.
On paper, that leaves a way out. In practice, it almost never opens. From our experience of double materiality analyses, it is very hard for a company to conclude that climate is not a material topic, whether on the impact side or on its exposure to transition risks. Companies subject to the CSRD therefore almost systematically end up having to deal with the carbon topic.
Yet ESRS E1 requires you to publish your greenhouse gas emissions across scopes 1, 2 and 3. You cannot answer it without a carbon inventory. The footprint is not the obligation, it is the practical condition for it. For the general reporting framework, see the CSRD European directive and who must comply.
Who is still subject to the CSRD after the Omnibus?
Far fewer companies than initially planned. The directive known as Omnibus, adopted on December 16, 2025, raised the application thresholds: the CSRD now targets companies with more than 1,000 employees and more than €450M in net turnover. The two criteria are cumulative. According to the French State's Portail RSE, this increase reduces the number of companies covered by around 80%.
Two other changes matter. The sector-specific standards were dropped, which makes the double materiality analysis all the more decisive in pinning down your topics. And companies that have fallen below the threshold can adopt the voluntary VSME standard, designed for SMEs, to keep structuring and communicating their approach without the burden of mandatory reporting. The detail of its voluntary nature is covered in VSME: mandatory or voluntary?.
In other words, leaving the scope of the CSRD does not make the demand disappear. Your customers subject to the directive must fill in their scope 3, which includes your emissions: they will therefore keep asking you for carbon data, as detailed in VSME for suppliers to large groups. That same demand travels through the channels you already know, starting with EcoVadis assessments and CDP questionnaires. A well-built carbon footprint feeds all three: your VSME reporting, your responses to assessments, and your customers' scope 3.
What does the CSRD require on carbon?
ESRS E1 covers climate from end to end. The most structuring requirements on the carbon side:
- your gross emissions across scopes 1, 2 and 3, with the methodology used;
- your emission reduction targets, quantified and dated;
- a transition plan for climate change mitigation, aligned with limiting warming to 1.5°C, describing the decarbonization levers, the associated investments and the share of emissions locked in by your existing assets;
- your energy consumption and energy mix.
Scope 3 is unavoidable here: it concentrates most of the footprint for most companies, and ESRS E1 expects coverage of significant indirect emissions.
What is the difference between BEGES and CSRD?
Two distinct obligations, French and European, that overlap without merging.
| Criterion | BEGES | CSRD (ESRS E1) |
|---|---|---|
| Nature | French obligation to measure and publish emissions | European sustainability reporting obligation |
| Carbon scope | Scopes 1 and 2; scope 3 only if the company is subject to the CSRD | Significant scopes 1, 2 and 3 |
| Transition plan | Minimum content set by article R229-47 | Detailed plan, 1.5°C aligned, with levers and investments |
| Publication | ADEME's Bilans GES platform | The company's sustainability report |
The detail of the French obligation appears in our article on the mandatory carbon footprint (BEGES), and the comparison of the two transition plans in our article on the transition plan.
Can you reuse your carbon footprint for the CSRD?
Yes, and that is the whole point of building it well. A carbon footprint covering scopes 1, 2 and 3, with a documented methodology and traceable factors, directly provides the material for the ESRS E1 emission indicators. Your reduction target and your transition plan feed the other requirements.
The CSRD goes further on detail (1.5°C alignment, investments, locked-in emissions), but it does not start from scratch. Measure once, use everywhere, including on your EcoVadis assessments and your CDP responses.
The same data feeds the CDP questionnaire. What overlaps and what is missing is detailed in our article on CDP, the carbon footprint and BEGES.
Prepare your CSRD climate section with Ditto
Ditto centralizes your carbon data into a single source, covers scopes 1, 2 and 3, keeps factor traceability and links your targets to a transition plan tracked over time.
The point that makes the difference is calibration. A carbon footprint does not have to be identical whatever its destination: for an EcoVadis assessment, a simple but well-built footprint unlocks most of the points; for ESRS E1, you need to cover significant scope 3, provide methodological traceability and the detailed transition plan. Ditto can produce a footprint sized for the CSRD from the start, rather than making you redo the exercise once the deadline is known. You do it once, and well.
This same base then serves your CSRD reporting, your VSME report if you are below the threshold, your EcoVadis assessments and your CDP responses, with no double entry. Ditto also supports the writing of your sustainability reports, drawing on your figures rather than on risky wording. A dedicated coach teaches you the method so you can run it yourself in the next cycle.
Connect your carbon footprint to your CSRD reporting
A Ditto expert reviews your climate data and what ESRS E1 expects of you.
Carbon footprint and CSRD: key takeaways
| Element | Summary |
|---|---|
| Obligation | The CSRD does not require "a carbon footprint", but ESRS E1 requires you to publish your emissions |
| Scope (Omnibus) | More than 1,000 employees AND more than €450M in net turnover (cumulative); VSME voluntary below |
| Carbon scope | Significant scopes 1, 2 and 3 |
| Key requirements | Emissions, quantified targets, 1.5°C-aligned transition plan, energy |
| BEGES difference | Distinct frameworks; BEGES only requires scope 3 if you are subject to the CSRD |
| Reuse | A well-built footprint directly feeds ESRS E1, EcoVadis and CDP |
| Entry point | The double materiality analysis |
Frequently asked questions
Is a carbon footprint mandatory for the CSRD?
Not as such. The CSRD requires sustainability information, including the ESRS E1 climate standard, which requires you to publish your emissions across scopes 1, 2 and 3. In practice, you cannot answer it without a carbon inventory: the footprint is the condition, not the obligation. And it is very rare for a company to conclude that climate is not a material topic.
Who is still subject to the CSRD after the Omnibus?
The Omnibus directive, adopted on December 16, 2025, raised the thresholds: the CSRD now targets companies with more than 1,000 employees and more than €450M in net turnover, with the two criteria being cumulative. This reduces the number of companies covered by around 80%. Below the threshold, the voluntary VSME standard takes over.
What does the CSRD require on carbon?
Your gross emissions across scopes 1, 2 and 3 and the methodology used, your quantified reduction targets, a transition plan for climate change mitigation aligned with 1.5°C (decarbonization levers, investments, locked-in emissions), and your energy data.
What is the difference between BEGES and CSRD?
BEGES is a French obligation to measure and publish emissions (scopes 1 and 2, scope 3 only if the company is subject to the CSRD), published on ADEME's platform. The CSRD is a European sustainability reporting obligation, whose climate section (ESRS E1) is significantly more detailed.
Can you reuse your carbon footprint for CSRD reporting?
Yes. A footprint covering scopes 1, 2 and 3, with a documented methodology and traceable factors, directly feeds the ESRS E1 emission indicators, as well as your targets and your transition plan. The CSRD goes further on detail, but does not start from scratch.
