CSRD fact sheet
Corporate Sustainability Reporting Directive
Type : Regulatory reporting
Date : Directive adopted in 2022
Implementation : 2024 for first publication in 2025
Author : European Commission
Target : Companies
Adopted in 2014 as part of the European Green Deal, the has until now framed European companies' non-financial performance disclosures. The NFRD was then implemented in France via the . 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 companies' non‑financial reporting system by integrating new measures (standards, comparability, external assurance).
What are the objectives of the approach?
The series of new CSRD standards aims to improve companies' ESG reporting at the European level by promoting better transparency and standardisation of companies' non‑financial disclosures. The CSRD aims to increase investors' and consumers' confidence 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 accordance with the European sustainability reporting 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 with 11,700 currently under the NFRD. This gap can be attributed to the extension of the scope to smaller entities.
The alignment obligations to the CSRD begin as early as 2024 and extend until 2028:
From the 2024 financial year (publication in 2025): large undertakings (in Europe and outside Europe) meeting 2 of the following 3 criteria: more than 500 employees, more than €25 million in total assets and/or €50 million in turnover already subject to the NFRD
From the 2025 financial year (publication in 2026): large undertakings not subject to the NFRD and that meet 2 of the following 3 criteria: more than 250 employees, €25 million in total assets and/or €50 million in turnover.
From the 2026 financial year (publication in 2027, possible derogation until 2028): the
Does the approach rely on a shared scientific basis?
The was appointed by the European Commission to develop detailed reporting standards: the ESRS. These aim to facilitate the comparison of European companies' non‑financial reports. Currently, there are 12. New sectoral standards or standards specific to listed SMEs on regulated markets will be introduced soon.
Does the approach rely on a specific methodology?
The new CSRD introduces the notion of double materiality, which consists of analysing all ESG criteria (environmental, social, governance) through a dual lens:
the financial materiality : impacts of sustainability matters on the company's financial performance
the 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 prepare its report in accordance with the ESRS. Only the general disclosures remain mandatory to provide within the reporting framework. For the other ESRS, it is for the company to specify what it considers relevant to publish following its double materiality analysis. However, it must be able to justify its choices on the basis of that analysis. Only companies that do not include ESRS E1 “Climate change” are required to publish a justification systematically.
In principle, the entire value chain, including scope 3, must be taken into account (provided that this corresponds to the spectrum covered by the double materiality analysis). The data must relate to the previous financial year, similar to financial reporting: a publication in 2024 will therefore be based on 2023 data. The organisation must present its current base year and must update it for its GHG emissions reduction targets 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 may be required to disclose under the CSRD. These data are linked to crucial aspects of the company, such as its financial, environmental, social and governance performance. To publish these specific pieces of information, companies must collect and present , amounting to a total of 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 later.
The CSRD requires a transition plan including a specific action plan for decarbonisation. This plan must detail emission reduction targets, adaptation policies and any other relevant initiatives to address climate impacts. It must include one or more emission reduction trajectories consistent with current carbon budgets (such as those of the SBTi) and a detailed action plan, quantifying the measures envisaged to achieve these targets.
Does the approach rely on tools?
No calculation tool is provided. However, a specific reporting format is required: ESRS XBRL (eXtended Business Reporting Language). This choice is intended to strengthen transparency and comparability. Reports are then published on an open access platform: the.
Can other low-carbon transition methods and tools be used to achieve the objectives of this approach?
Among the DRs that address environmental aspects, those dealing with carbon‑related issues are grouped inESRS E1 titled “Climate change” and partly in ESRS 2 “Pollution”. To provide comprehensive information, both quantitative and qualitative, different methods and tools can be used as support to obtain this information. Indeed, conducting a Bilan Carbone® or participating in the ACT® programme enable organisations to meet the requirements of ESRS E1.
For example, during the data collection and processing step of the Bilan Carbone®, the information necessary for DR 5 on energy consumption and the energy mix, as well as for DR 6 on gross GHG emissions for scopes 1, 2, 3 and total GHGs, can be obtained. Similarly, the action plan step of the Bilan Carbone® would provide qualitative information for the DR concerning the transition plan for climate change mitigation, as well as for the DR on targets related to mitigation and adaptation to climate change.
As for the ACT® programme, it can provide relevant elements on the organisation's low‑carbon strategy and transition trajectories, as required in the DR on policies related to mitigation and adaptation to climate change, as well as in the DR on actions and resources associated with climate policies.
Does it allow third-party recognition? If so, in what way?
The CSRD makes third‑party assurance and audit of the disclosed information mandatory, rather than internal assurance as was the case under the NFRD.
The sustainability report will be assured by:
an auditor
or an independent third‑party body (ITP)
ITPs will have to receive accreditation from the , and all auditors will be under the supervision of the .
In case of non‑compliance with the CSRD, sanctions have been foreseen :
€3,750 will be payable in the event of non‑publication of the report or publication of partial or incorrect information.
In the event of failure to audit the non‑financial report, a fine of up to €30,000 and a custodial sentence of up to 2 years may be imposed.
In the event of obstruction to auditors' verifications or controls, a fine of up to €75,000 and a custodial sentence of up to 5 years may be imposed. In addition, indicators must be reviewed every three years.
Besides these sanctions, other measures may be envisaged:
Reputational sanction: public disclosure of the company's name and the nature of the offence.
Regulatory sanction: order to cease activity related to the offence.
Financial sanction: imposition of a fine proportionate to the company's financial situation and the benefits derived from the offence.
Can this approach be harmonised with other international frameworks?
In order to avoid the multiplication and competition between international standards, the CSRD was designed as a framework compatible with other reference frameworks.
For harmonisation with US standards, a correspondence table between IFRS and ESRS was published in 2023, showing strong convergence on the financial materiality of climate issues between EFRAG and the.
EFRAG has 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 after consultation with business representatives.
The sheets of the Overview of carbon accounting methods and tools are the result of a synthesis work by ABC. We remain open to your feedback or questions on this form.
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