> For the complete documentation index, see [llms.txt](https://www.bilancarbone-methode.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://www.bilancarbone-methode.com/english/annexes/bibliographie/fiche-csrd.md). # CSRD fact sheet {% hint style="success" %} **Type**: Regulatory reporting **Date**: Directive adopted in 2022 **Implementation**: 2024 for first publication in 2025 **Author**: European Commission **Target**: Companies {% endhint %} Adopted in 2014 within the framework of the European Green Deal, the NFRD[^1] until now governed the non-financial performance declarations of European companies. The NFRD was applied in France via the DPEF[^2]. Considered incomplete, this first directive is set to be replaced and consolidated in 2025 by the CSRD. The **CSRD (Corporate Sustainability Reporting Directive)** is thus the new directive proposed by the European Commission that aims to strengthen the non-financial reporting system of companies, through the integration of new measures (standards, comparability, external verification). ## **What are the objectives of the approach?** The series of new CSRD standards aims to **improve the ESG reporting of companies at the European level** by promoting better **transparency** and **standardisation** of non-financial disclosures of companies. The CSRD aims to increase the confidence of investors and consumers in the data provided by companies while facilitating their interoperability. From 2025, the companies concerned will have to include in their management reports indicators in compliance with European sustainable development standards, the **European Sustainability Reporting Standards (ESRS)**. ## **What is (are) the target(s) of the approach?** The CSRD is intended for European companies and will ultimately affect around 50,000 companies, compared to 11,700 currently with the NFRD. This gap can be attributed to the extension of the scope to smaller-sized structures. The [alignment obligations](https://eur-lex.europa.eu/legal-content/FR/TXT/PDF/?uri=OJ:L_202302775) to the CSRD begin from 2024 and extend through to 2028: * From the 2024 financial year (publication in 2025): **large companies** (European and non-European) meeting 2 of the following 3 criteria: more than 500 employees, more than €25 million in balance sheet and/or €50 million in turnover **already subject to the NFRD** * From the 2025 financial year (publication in 2026): **large companies not subject to the NFRD** meeting 2 of the following 3 criteria: more than 250 employees, €25 million in balance sheet and/or €50 million in turnover. * From the 2026 financial year (publication in 2027, deferral possible until 2028): [**listed SMEs**](#user-content-fn-3)[^3] {% hint style="info" %} These figures were revised by the European Commission in 2023 and have been transposed into French national law in [Ordinance No. 2023-1142.](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000048519395) {% endhint %} ## **Does the approach draw on a shared scientific basis?** [**EFRAG**](#user-content-fn-4)[^4] has been appointed by the European Commission to develop precise reporting standards: the ESRS. These aim to facilitate the comparison of non-financial reports of European companies. There are currently 12. New sectoral standards or those specific to SMEs listed on regulated markets will shortly be introduced.
The first two ESRS "General Disclosure" have a general and transversal scope. ESRS 1 "General Principles": defines the architecture, principles and general concepts of the ESRS standards, including the characteristics and structure of information, double materiality... ESRS 2 "General Information": details the information that companies must present in connection with material sustainability topics. This information covers four reporting domains: governance, strategy, the process of identifying and managing sustainability impacts, risks and opportunities, as well as sustainability indicators and objectives.
Among the 10 thematic ESRS, 5 criteria are related to the environmental dimension. * **ESRS E1: Climate change** * **ESRS E2: Pollution** * **ESRS E3: Marine and water resources** * **ESRS E4: Biodiversity and ecosystems** * **ESRS E5: Resource use and circular economy** * ESRS S1: Own workforce * ESRS S2: Workers in the value chain * ESRS S3: Affected communities * ESRS S4: Consumers and end-users * ESRS G1: Business conduct
## **Does the approach draw on a specific methodology?** The new CSRD directive introduces the notion of double materiality, which consists of analysing all ESG criteria (environmental, social, governance) through a dual lens: * **financial materiality**: impacts of sustainability issues on the company's financial performance * **impact materiality**: impacts of the company on its economic, social and natural environment Once the double materiality analysis has been carried out, the organisation must draft its report according to the ESRS standards. **Only general information remains mandatory to provide** within the framework of the reporting. For the other ESRS, it is for the company to specify what it deems **relevant** to publish following its double materiality analysis. However, it must be in a position to justify its choices on the basis of this analysis. Only companies that do not integrate ESRS E1 "Climate Change" must systematically publish a justification. **In principle, the entire value chain, including scope 3, must be taken into account (insofar as this corresponds to the spectrum covered by the double materiality analysis)**. Data must relate to the previous fiscal year, similar to financial reporting: a publication in 2024 will thus be based on 2023 data. The organisation must present its current reference year and must update it for its GHG emission reduction objectives **every 5 years after 2030**. **Each ESRS includes a set of DRs** (82 in total, of which 32 relate to the environment), representing the specific information that companies are potentially required to disclose within the framework of the CSRD. This data is linked to crucial aspects of the company, such as its financial, environmental, social and governance performance. To publish this specific information, companies must collect and present [**data points**](#user-content-fn-5)[^5], totalling around 1,200. **Each DR is associated with data points**, which can be narrative, semi-narrative, percentages or monetary data. The number of DRs and data points may evolve subsequently. **The CSRD requires a transition plan including a specific action plan for decarbonisation.** This plan must detail the emission reduction objectives, adaptation policies and any other relevant initiative to address climate impacts. It must include one or more emission reduction pathways consistent with applicable carbon budgets (such as those of the SBTi) and a detailed action plan, quantifying the measures envisaged to achieve these objectives.
Furthermore, relief measures are planned for certain companies to facilitate the transition from the NFRD to the CSRD. * All companies will be able to defer by one year the consideration of anticipated financial effects of physical and transition climate risks. * Possibility of deferring by one year the publication of scope 3 greenhouse gas emissions and deferring by two years the application of the biodiversity standard for companies with fewer than 750 employees * Simplified reporting for SMEs who need only comply with 6 standards and several DRs[^6] become optional.
## **Does the approach draw on tools?** **No calculation tool is proposed**. However, a specific reporting format is required: ESRS XBRL (eXtended Business Reporting Language). This choice is intended to enhance transparency and comparability. Reports are then published on a freely accessible platform: the [**ESAP**](#user-content-fn-7)[^7]. ## **Can other low-carbon transition methods and tools be used to achieve the objectives of this approach?** Among the DRs dealing with environmental aspects, those relating to carbon-related issues are grouped in **ESRS E1 entitled "Climate Change"** and partly in ESRS 2 "Pollution". To provide complete information, both quantitative and qualitative, various methods and tools can be used as support to obtain this information. Indeed, **carrying out a Bilan Carbone® or participating in the ACT® programme enables organisations to meet the requirements of ESRS E1**. For example, during the data collection and analysis stage of the Bilan Carbone®, the information necessary for DR 5 on energy consumption and energy mix, as well as for DR 6 on gross GHG emissions from scopes 1, 2, 3 and total GHGs, can be obtained. Similarly, the Bilan Carbone® reduction action plan stage would enable qualitative information to be provided for the DR relating to the transition plan for climate change mitigation, as well as for the DR on objectives linked to climate change mitigation and adaptation. As for the ACT® programme, it can contribute relevant elements on the organisation's low-carbon transition strategy and pathways, as required in the DR on policies relating to climate change mitigation and adaptation, as well as in the DR on actions and associated resources for policies to combat climate change. ## **Does it allow for third-party recognition? If so, in what way?** The CSRD makes it mandatory to carry out verification and an audit of communicated information by a third party, and not internally as was the case with the NFRD. The sustainability report will be verified by: * **a statutory auditor** * **or an independent third-party body (OTI)** OTIs will need to receive accreditation from the COFRAC[^8], and all auditors will be under the supervision of the H2A[^9]. In the event of non-compliance with the CSRD, **penalties have been provided for**: * €3,750 will be payable in the event of non-publication of the report or publication of partial or erroneous information. * In the event of a non-audit of the non-financial report, a fine of up to €30,000 and a prison sentence of up to 2 years may be imposed. * In the event of obstruction of auditors' verifications or checks, a fine of up to €75,000 and a prison sentence of up to 5 years may be pronounced. In addition, indicators must be reviewed every three years. In addition to these penalties, other measures may be envisaged: * Reputational sanction: public disclosure of the company name and the nature of the infringement. * Regulatory sanction: order to cease activities related to the infringement. * Financial sanction: imposition of a fine proportional to the company's financial situation and the benefits derived from the infringement. {% hint style="info" %} These penalties vary depending on the transposition of the CSRD into the national law of each EU member state. For example, in the Netherlands, they can reach up to €10 million or 5% of the company's annual turnover. {% endhint %} ## **Can this approach be harmonised with other international reference frameworks?** In order to avoid the multiplication and competition between international standards, the CSRD has been designed as a **framework compatible with other reference frameworks**. For harmonisation issues with American standards, a correspondence table between IFRS and ESRS standards was published in 2023, showing strong convergence on the financial materiality of climate issues between EFRAG and the ISSB[^10]. EFRAG also signed a compatibility protocol with the GRI. In this context of standards harmonisation, the future Climate Indicator of the Banque de France will be aligned with the CSRD directive following consultation with business representatives. *** *The sheets from the* [*Overview of carbon accounting methods and tools*](/english/annexes/bibliographie.md#labc-et-les-ressources-complementaires-au-bilan-carbone-r) *are the result of a synthesis work by the ABC. We welcome your feedback or questions via this* [*form*](https://fr.surveymonkey.com/r/RetoursUtilisateurs)*.* [^1]: Non Financial Reporting Directive [^2]: Déclaration de Performance Extra-Financière (Non-Financial Performance Declaration) [^3]: (excluding micro-enterprises with fewer than 10 employees whose total balance sheet does not exceed €450,000 or whose net turnover does not exceed €900,000) [^4]: **European Financial Reporting Advisory Group** [^5]: data points [^6]: Disclosure Requirements [^7]: European Single Access Point [^8]: Comité Français d'Accréditation (French Accreditation Committee) [^9]: Haute autorité de l'audit (High Audit Authority) [^10]: International Sustainability Standards Board --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. 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