CSRD obligations: what must companies disclose?

Why the CSRD changes the game

The CSRD significantly raises non-financial reporting requirements. It replaces the NFRD and requires certain companies to publish a sustainability report integrated into their management report. Its goal: harmonize and strengthen ESG disclosure across the EU so investors, customers and regulators can compare performance on a common basis. For the full picture, see the CSRD directive.

Who must comply with the CSRD?

The directive targets large companies and significant public-interest entities. Who is concerned is set by the Accounting Directive 2013/34/EU thresholds (balance sheet, net turnover, average headcount). The 2026 Omnibus I adjustment refocused scope on companies with more than 1,000 employees and €450M net turnover, while keeping strict obligations for large groups and listed companies. SMEs are increasingly solicited by their CSRD-bound customers.

The reporting obligations imposed by the CSRD

Companies must publish a report structured around the ESRS (12 ESG topics across environment, social, governance). Key requirements:

• Double materiality: assess both the company's impacts on society and the environment and the ESG risks affecting its financial performance, via a double materiality analysis.
• Quantitative and qualitative indicators: answer normalized data points (the draft revised ESRS reduce mandatory datapoints by over 60%).
• Mandatory assurance: each report is verified by a third-party auditor.
• Integration into the management report: sustainability data is no longer a separate document, feeding overall non-financial reporting.

How to prepare for CSRD compliance

Moving from a voluntary logic (ISO, EcoVadis, GRI) to a regulatory framework requires a robust organization:

1. Governance: set up an ESG committee involving finance, legal, HR and operations.
2. Data collection: establish regular reporting cycles for verifiable data (emissions, HR, human rights, governance).
3. Internal controls and audit: document calculation methods and anticipate the auditor's checks, drawing on CSR audit practices.
4. Information systems: centralize ESG data in a single management platform to avoid inconsistencies and ease assurance.

For SMEs, structuring data along the VSME standard helps anticipate customer requests and future obligations.

Sector and value-chain implications

High-impact companies (energy, manufacturing, finance, agriculture) must disclose specific information on indirect emissions, transition plans and resource management. The CSRD also requires collecting ESG information across the value chain (suppliers, subcontractors, partners), imposing new traceability and supplier-engagement mechanisms, even for SMEs not directly in scope.

Penalties and compliance oversight

National authorities supervise CSRD compliance. Companies face administrative or financial penalties, and reputational damage, in case of failures in disclosure, quality or assurance. Beyond compliance, the stakes touch the company's ESG credibility with investors and customers.

CSRD obligations: key takeaways