Last updated: May 2026. This guide reflects the Omnibus I Directive, which entered into force on 18 March 2026 and significantly revised CSRD scope, timelines, and reporting standards.

Executive Summary

The Corporate Sustainability Reporting Directive (CSRD) is the European Union’s law governing how large companies disclose information about their environmental, social, and governance (ESG) performance. It requires in-scope companies to publish standardized, independently assured sustainability data alongside their financial statements, using the European Sustainability Reporting Standards (ESRS).

CSRD matters because it converts sustainability reporting from a voluntary, fragmented exercise into a regulated discipline with the same rigor as financial accounting. For investors, it produces comparable ESG data across the European market. For companies, it makes sustainability a board-level governance and assurance obligation rather than a marketing function.

The regulatory picture changed substantially in early 2026. The EU’s Omnibus I simplification package, which became law in March 2026, raised the size thresholds for mandatory reporting, removed listed small and medium-sized enterprises from scope, delayed first reports for the next group of companies to 2028, and instructed the EU to simplify the ESRS. The result: an estimated 80 to 90 percent of companies once expected to report are no longer required to. The core architecture of CSRD, however, remains intact — double materiality, mandatory assurance, and ESRS-based disclosure all continue to apply to the largest companies operating in Europe.

What Is CSRD?

The Corporate Sustainability Reporting Directive (CSRD) is the European Union’s legal framework for corporate sustainability reporting. It defines which companies must disclose sustainability information, what they must report, and how that information must be prepared, verified, and published.

CSRD entered into force in January 2023 and replaced the earlier Non-Financial Reporting Directive (NFRD). It expanded both the number of companies covered and the depth of required disclosure. In-scope companies must report under the European Sustainability Reporting Standards (ESRS) and have their sustainability disclosures independently assured — a significant departure from the largely unverified, voluntary reporting that preceded it.

The directive’s purpose is to give investors, regulators, civil society, and business partners reliable, comparable, and decision-useful information about how companies affect the environment and society, and how sustainability issues in turn affect a company’s financial position. In doing so, CSRD aims to direct capital toward more sustainable activities and to support the goals of the European Green Deal.

In one sentence: CSRD is the EU directive that requires large companies to publish audited, standardized sustainability information using the European Sustainability Reporting Standards, based on the principle of double materiality.

Why CSRD Matters

CSRD is widely regarded as the most consequential sustainability regulation in the world, and its significance extends well beyond European borders.

It standardizes ESG data. Before CSRD, sustainability disclosures were voluntary and built on a patchwork of competing frameworks. Two companies could each call themselves “sustainable” while measuring entirely different things. CSRD imposes a common reporting language — the ESRS — so that stakeholders can compare disclosures across companies, sectors, and countries.

It responds to investor demand. Asset managers, banks, insurers, and rating agencies have integrated ESG factors into risk modeling, capital allocation, and lending decisions. They need consistent, verifiable data to do so credibly. CSRD supplies that data and supports related EU rules such as the Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy.

It treats sustainability as governance. Because CSRD disclosures sit inside the management report and must be assured, accountability moves to the board and the audit committee. Sustainability becomes a matter of internal controls, data integrity, and director responsibility — not corporate communications.

It has global reach. Non-EU companies with substantial EU operations can fall within scope, and multinationals frequently apply CSRD-grade processes across their entire group for consistency. CSRD has effectively become a global benchmark for what credible sustainability reporting looks like.

CSRD Background and Evolution

CSRD did not appear in isolation. It is the product of a decade of escalating EU ambition on corporate transparency and sustainable finance.

From NFRD to CSRD. The Non-Financial Reporting Directive (NFRD), in force from 2018, was the EU’s first attempt at mandatory sustainability disclosure. It applied only to large public-interest entities with more than 500 employees — roughly 11,700 companies — and gave them wide latitude over what and how to report. The result was inconsistent, often unverified, and difficult to compare. Investors and regulators concluded that NFRD did not produce reliable data.

The European Green Deal context. CSRD is a pillar of the European Green Deal, the EU’s strategy to reach climate neutrality by 2050. The Green Deal depends on redirecting private capital toward sustainable activities, and capital cannot flow efficiently without trustworthy information. CSRD was designed to be the disclosure backbone of that system, working alongside the EU Taxonomy and SFDR.

Why the EU expanded the rules. CSRD widened the scope of mandatory reporting, introduced the binding ESRS, mandated independent assurance, required digital tagging of disclosures, and embedded the concept of double materiality. The objective was to close the credibility gap left by NFRD and to put sustainability information on a comparable footing with financial information.

The Omnibus correction. By 2024 and 2025, concerns about compliance cost and European competitiveness prompted a recalibration. In February 2025 the European Commission proposed the Omnibus I simplification package. After negotiation among the Commission, the European Parliament, and the Council, the EU adopted the final text on 24 February 2026, and it entered into force on 18 March 2026. Omnibus I did not repeal CSRD, but it materially narrowed who must comply and simplified what they must disclose. The current CSRD is best understood as CSRD as amended by Omnibus I.

Who Must Comply With CSRD?

This is the area most reshaped by the Omnibus I Directive. The original CSRD used a phased, four-wave rollout with relatively low thresholds. Omnibus I raised those thresholds sharply and removed entire categories of company from scope.

The current scope threshold. Under CSRD as amended by Omnibus I, mandatory reporting generally applies to large companies that exceed both of the following on a consolidated basis:

  • more than 1,000 employees, and
  • more than €450 million in annual net turnover.

Both conditions must be met. This is a substantial increase from the original CSRD thresholds and is the single biggest reason that, by most estimates, 80 to 90 percent of previously in-scope companies are no longer required to report.

Listed companies. Large companies listed on EU-regulated markets remain in scope if they meet the size thresholds above. Critically, listed small and medium-sized enterprises (SMEs) have been removed entirely from mandatory CSRD scope by Omnibus I. The original “Wave 3” category of listed SMEs effectively no longer exists; these companies are instead encouraged to report voluntarily under the simplified VSME standard.

Non-EU companies. Non-EU parent companies can still fall within scope where they generate significant net turnover in the EU and have an EU subsidiary or branch above defined size limits. Multinational groups headquartered outside the EU should assess their EU footprint carefully, as group-level reporting obligations can be triggered by EU operations.

Wave 1 transition relief. Companies already reporting under NFRD that began CSRD reporting for financial year 2024 (“Wave 1”) but no longer meet the new, higher thresholds may be exempted from reporting for financial years 2025 and 2026. This relief is not automatic — it is subject to how each EU member state transposes the directive, so it must be confirmed jurisdiction by jurisdiction.

CSRD Timelines After Omnibus I

Company group Description First CSRD report Financial year covered
Wave 1 Companies previously under NFRD (large public-interest entities, 500+ employees) that meet the revised thresholds Already reporting (first reports published 2025) FY2024 onward
Wave 2 Other large companies meeting the 1,000-employee and €450M-turnover thresholds 2028 FY2027
Wave 3 (listed SMEs) Listed small and medium-sized enterprises Removed from mandatory scope; voluntary VSME reporting encouraged Not applicable

The revised scope thresholds apply to financial years beginning on or after 1 January 2027. EU member states have until 19 March 2027 to transpose the Omnibus I directive into national law, so precise filing and publication rules will vary by country.

What Must Companies Report Under CSRD?

CSRD requires disclosure across environmental, social, and governance topics, prepared according to the European Sustainability Reporting Standards. The reporting covers both the company’s own operations and, within defined limits, its value chain.

Environmental disclosures address climate change, including greenhouse gas emissions and climate-related risks; pollution; water and marine resources; biodiversity and ecosystems; and resource use and the circular economy.

Social disclosures cover a company’s own workforce, including working conditions, equal treatment, and health and safety; workers in the value chain; affected communities; and consumers and end users.

Governance disclosures address business conduct, including corporate culture, anti-corruption and anti-bribery measures, political engagement, and the management of supplier relationships and payment practices.

Climate and emissions reporting. Climate is typically the most demanding area. Companies generally report greenhouse gas emissions across Scope 1 (direct emissions), Scope 2 (purchased energy), and Scope 3 (value chain emissions), and disclose climate-related risks, targets, and — where material — transition plans toward climate neutrality.

Value chain reporting. CSRD looks beyond a company’s own walls to its supply chain. To prevent disproportionate burden on smaller suppliers, Omnibus I introduced a “value chain cap” that protects companies with fewer than 1,000 employees from data requests exceeding a defined voluntary standard, and reporting companies have a multi-year grace period for value chain disclosures where data is not yet available.

Format requirements. Companies report sustainability information within the management report — not in a separate brochure — and digitally tag it so machines can read it and aggregate it at the European level.

What Is Double Materiality?

Double materiality is the foundational principle of CSRD and the concept that most distinguishes it from other reporting regimes.

Double materiality means a company must report on a sustainability topic if it is significant from either of two perspectives — its impact on the world, or its effect on the company’s own finances — not only when both apply.

The two perspectives are:

  • Impact materiality (inside-out): how the company’s activities affect people and the environment — for example, the emissions it produces or the labor conditions in its operations.
  • Financial materiality (outside-in): how sustainability issues affect the company’s financial position, performance, cash flows, access to finance, or cost of capital — for example, physical climate risk to facilities or carbon pricing exposure.

A topic is reportable if it is material under either lens. This is a deliberately broader test than the “financial materiality only” approach used by investor-focused frameworks. It reflects the EU’s view that companies are accountable both to their investors and to society.

Double materiality remains mandatory under CSRD after Omnibus I. While the simplified ESRS reduce the number of required data points, the double materiality assessment becomes more important, not less — it is the mechanism that determines which disclosures a company must make, and it must be supported by clear evidence and reasoning.

What Are ESRS Standards?

The European Sustainability Reporting Standards (ESRS) are the detailed technical standards that specify exactly what in-scope companies must disclose under CSRD. If CSRD is the law, the ESRS are the rulebook that operationalizes it.

The European Financial Reporting Advisory Group (EFRAG) developed the ESRS, and the European Commission adopted them. The first set comprises 12 standards: two cross-cutting standards covering general principles and general disclosures, and ten topical standards covering environmental, social, and governance subjects.

The standards are organized as follows:

  • Cross-cutting: ESRS 1 (general requirements) and ESRS 2 (general disclosures).
  • Environmental: climate change, pollution, water and marine resources, biodiversity and ecosystems, and resource use and circular economy.
  • Social: own workforce, value chain workers, affected communities, and consumers and end users.
  • Governance: business conduct.

What a company actually discloses depends on its double materiality assessment: the general disclosures apply to everyone, while topical disclosures apply where the underlying topic is material.

The Amended ESRS. As part of Omnibus I, the European Commission asked EFRAG to simplify the standards. EFRAG delivered draft Amended ESRS that cut the number of mandatory data points by roughly 60 percent, clarify language, and place greater weight on materiality and professional judgment. The Commission is expected to adopt the simplified standards as a delegated act, with the aim of having them available for FY2027 reporting and potentially for voluntary earlier use. Until the delegated act takes effect, Wave 1 companies continue to apply the original first set of ESRS.

CSRD vs Other ESG Reporting Frameworks

CSRD does not exist in a vacuum. Understanding how it relates to other major frameworks clarifies what makes it distinctive.

Framework Issuing body Materiality approach Mandatory? Primary focus
CSRD / ESRS European Union / EFRAG Double materiality Yes, for in-scope companies Comprehensive ESG disclosure for EU and EU-active companies
ISSB (IFRS S1 & S2) IFRS Foundation Financial materiality Depends on national adoption Investor-focused, sustainability-related financial disclosure
GRI Global Reporting Initiative Impact materiality Voluntary A company’s impacts on economy, environment, and people
SASB Now part of the ISSB Financial materiality Voluntary Industry-specific, financially material ESG metrics
TCFD Financial Stability Board (recommendations now under ISSB) Financial materiality Voluntary / referenced by regulators Climate-related financial risk and governance
SEC climate disclosure rules U.S. Securities and Exchange Commission Financial materiality Subject to U.S. legal and regulatory developments Climate risk disclosure for U.S. registrants

The defining difference is materiality. CSRD’s double materiality requires companies to report both their effect on the world and the world’s effect on them. The ISSB, SASB, TCFD, and the SEC framework concentrate on financial materiality — sustainability issues that affect enterprise value. GRI sits at the other end, focused on impact. EFRAG drafted the ESRS to interoperate closely with the ISSB and GRI frameworks, so that companies can collect data once and use it to meet multiple reporting obligations.

Business Implications of CSRD

CSRD reaches across an organization and its network of relationships.

Public and large private companies in scope must build durable reporting infrastructure: a defensible double materiality assessment, auditable data systems, board-level governance of sustainability, and readiness for independent assurance. For many, this is a multi-year transformation rather than a reporting project.

Investors and asset managers gain a richer, more comparable dataset to support portfolio analysis, risk assessment, and obligations under SFDR and the EU Taxonomy. CSRD data improves the quality of sustainable-finance decision-making across the European market.

Multinational corporations face the question of whether to apply CSRD-grade processes globally or only where strictly required. Many opt for a single global standard to avoid running parallel systems and to satisfy investors and customers consistently.

Supply chains are affected even where individual suppliers are not directly in scope, because reporting companies need value chain data. Omnibus I’s value chain cap limits how much can be demanded from smaller suppliers, but suppliers to large companies should still expect sustainability data requests.

Finance teams and sustainability officers move closer together. CSRD effectively merges sustainability reporting with the discipline of financial reporting — shared controls, shared timelines, and shared accountability to the audit committee.

Challenges and Criticisms of CSRD

CSRD has drawn substantive criticism, and the Omnibus I package was a direct response to much of it.

Compliance complexity. The original ESRS contained over a thousand potential data points. Even after the Amended ESRS reduce that number significantly, building the assessment, governance, and assurance processes remains demanding.

Cost. Critics argued that reporting costs were disproportionate, especially for smaller companies, and that they risked undermining European competitiveness relative to firms in jurisdictions without comparable requirements.

Data collection. Scope 3 emissions and other value chain disclosures depend on information held by third parties. Gathering reliable data across complex, global supply chains is widely regarded as the single hardest part of compliance.

Regulatory uncertainty. The rapid sequence of changes — the original directive, the “stop-the-clock” delay, and then Omnibus I — created planning difficulty. Companies that invested early found the rules shifting beneath them.

Concerns about ambition. Some sustainability advocates argue that Omnibus I went too far, exempting most companies and weakening the EU’s transparency agenda. Supporters counter that a narrower, workable rule applied to the largest companies is more durable than an expansive one that provokes backlash.

Opportunities Created by CSRD

For companies that approach it strategically, CSRD is more than a compliance cost.

Transparency and trust. Credible, assured disclosure builds confidence with investors, customers, regulators, and employees, and helps separate substantive performers from those engaged in greenwashing.

Access to capital. High-quality sustainability data supports access to sustainable finance — green bonds, sustainability-linked loans, and ESG-oriented investment — and can influence the cost of capital.

Competitive differentiation. As ESG data becomes standardized, genuine sustainability leadership becomes visible and comparable, turning performance into a market advantage rather than an unverifiable claim.

Better risk management. The double materiality assessment is, in effect, a structured enterprise risk exercise. It surfaces climate, social, and governance risks that might otherwise go unmanaged.

Operational improvement. The data systems built for CSRD frequently reveal inefficiencies — in energy use, resource consumption, and supply chain management — that translate into cost savings.

The Future of Sustainability Reporting in Europe

CSRD will continue to evolve, and several trends are already visible.

Standards will keep simplifying. The Amended ESRS signal an ongoing effort to reduce burden while preserving decision-useful information. Expect continued refinement and sector-specific guidance.

Global convergence will continue. Interoperability between the ESRS and the ISSB standards is a priority for regulators and standard-setters alike. The long-term direction is toward a more unified global baseline for sustainability disclosure, even if regional differences persist.

Technology will reshape reporting. Digital tagging, automated data collection, and AI-assisted analysis are becoming central to how companies gather, validate, and assure sustainability data — and how investors consume it. AI-driven retrieval also means that clear, well-structured disclosure is increasingly read by machines, not only people.

Assurance will deepen. Sustainability reporting is on a path from limited assurance toward more rigorous verification over time, bringing it progressively closer to the standards applied to financial audit.

Practical Steps Companies Should Take Now

Whether a company is firmly in scope, newly out of scope, or uncertain, the post-Omnibus environment calls for deliberate action.

  1. Confirm your scope. Test your organization against the revised thresholds — more than 1,000 employees and more than €450 million in net turnover — using your most recent consolidated figures. Scope is now the first and most important question.
  2. Establish governance. Assign clear board and audit-committee oversight of sustainability reporting, and define accountability across finance, legal, and sustainability functions.
  3. Run or refresh your double materiality assessment. This determines what you must report. It should be evidence-based, documented, and defensible to an assurance provider.
  4. Build ESG data systems. Treat sustainability data with the same controls as financial data — defined ownership, audit trails, and consistent methodology — especially for greenhouse gas emissions.
  5. Prepare for assurance. Engage assurance providers early and ensure your data and processes can withstand independent verification.
  6. Use 2026 as a preparation year. For companies reporting first in 2028, 2026 and 2027 are for building capability — confirming scope, refining materiality, and establishing data processes — not for rushing a report.
  7. If newly out of scope, decide deliberately. Many exempt companies will still face ESG data requests from investors, lenders, and large customers. Voluntary reporting under the VSME standard may be the pragmatic choice.

Frequently Asked Questions About CSRD

What is CSRD?

CSRD is the Corporate Sustainability Reporting Directive, the European Union law that requires large companies to publish standardized, independently assured sustainability information using the European Sustainability Reporting Standards (ESRS), based on the principle of double materiality.

Who must comply with CSRD?

After the Omnibus I Directive, mandatory CSRD reporting generally applies to large companies that exceed both 1,000 employees and €450 million in annual net turnover, including qualifying EU-listed companies and certain non-EU companies with significant EU operations. Listed SMEs have been removed from mandatory scope.

What is double materiality?

Double materiality is the principle that a company must report a sustainability topic if it is significant either because of the company’s impact on people and the environment (impact materiality) or because the topic affects the company’s financial position (financial materiality). A topic is reportable if either test is met.

What are ESRS standards?

The European Sustainability Reporting Standards (ESRS) are the detailed technical standards, developed by EFRAG and adopted by the European Commission, that specify exactly what in-scope companies must disclose under CSRD. The first set contains 12 standards covering general, environmental, social, and governance topics.

Is CSRD mandatory?

Yes. CSRD is mandatory for companies that fall within its scope. Omnibus I narrowed that scope considerably, so fewer companies are now required to report, but for those that remain in scope, reporting and independent assurance are legal obligations.

When does CSRD take effect?

CSRD entered into force in 2023. Wave 1 companies are already reporting, with first reports published in 2025 for financial year 2024. Following the Omnibus I delay, the next group of large companies (Wave 2) will publish their first CSRD reports in 2028, covering financial year 2027.

How does CSRD compare to ISSB?

The main difference is materiality. CSRD applies double materiality, requiring disclosure of both a company’s impact on the world and sustainability’s effect on the company. The ISSB standards focus on financial materiality — sustainability information relevant to investors and enterprise value. EFRAG designed the ESRS to interoperate closely with the ISSB standards.

Does CSRD apply to U.S. companies?

It can. A U.S. company is not subject to CSRD simply because it is American, but it can fall within scope if it generates significant net turnover in the EU and has an EU subsidiary or branch above defined size thresholds. Many U.S. multinationals are affected through their European operations.

What changed under the Omnibus I package?

Omnibus I, which entered into force on 18 March 2026, raised the scope thresholds to more than 1,000 employees and more than €450 million in turnover, removed listed SMEs from mandatory scope, delayed first reports for Wave 2 companies to 2028, simplified the ESRS, and introduced protections that limit data requests on smaller value chain companies. It did not repeal CSRD; double materiality and mandatory assurance remain in place.

What is the difference between CSRD and ESRS?

CSRD is the law that establishes the obligation to report. The ESRS are the standards that specify what must be reported and how. In short, CSRD sets the requirement and the ESRS provide the detailed rulebook companies follow to meet it.

Does CSRD require assurance of sustainability data?

Yes. CSRD requires that sustainability disclosures be independently assured, initially at a limited assurance level. This is a defining feature of the directive and is the main reason sustainability reporting has moved under board and audit-committee oversight.

Conclusion

The Corporate Sustainability Reporting Directive remains the most influential sustainability regulation in the world, even after the Omnibus I package reshaped it. By requiring standardized, assured, double-materiality disclosure, CSRD has permanently raised the bar for what credible corporate sustainability reporting looks like — and that benchmark now shapes expectations far beyond the companies legally required to follow it.

Omnibus I narrowed the directive’s reach and simplified its demands, concentrating mandatory reporting on Europe’s largest companies. But it left the core intact. Double materiality still governs what must be reported. Independent assurance still applies. The European Sustainability Reporting Standards still define the disclosures. The shift was one of proportionality, not principle.

For executives, investors, and sustainability professionals, the strategic message is consistent regardless of scope. Sustainability data has become capital-market infrastructure. Banks, investors, insurers, rating agencies, and large customers continue to demand it. CSRD’s lasting contribution is that it set the global standard for how that information is prepared, verified, and trusted — and that standard is not going away.


ESG News provides independent reporting and analysis on sustainability, ESG regulation, climate finance, and corporate disclosure. This article is intended for informational purposes and does not constitute legal or compliance advice; companies should confirm their specific obligations against the national transposition of the Omnibus I Directive in each relevant EU member state.

What is CSRD?

CSRD is the Corporate Sustainability Reporting Directive, the European Union law that requires large companies to publish standardized, independently assured sustainability information using the European Sustainability Reporting Standards (ESRS), based on the principle of double materiality.

Who must comply with CSRD?

After the Omnibus I Directive, mandatory CSRD reporting generally applies to large companies that exceed both 1,000 employees and 450 million euros in annual net turnover, including qualifying EU-listed companies and certain non-EU companies with significant EU operations. Listed SMEs have been removed from mandatory scope.

What is double materiality?

Double materiality is the principle that a company must report a sustainability topic if it is significant either because of the company’s impact on people and the environment (impact materiality) or because the topic affects the company’s financial position (financial materiality). A topic is reportable if either test is met.

What are ESRS standards?

The European Sustainability Reporting Standards (ESRS) are the detailed technical standards, developed by EFRAG and adopted by the European Commission, that specify exactly what in-scope companies must disclose under CSRD. The first set contains 12 standards covering general, environmental, social, and governance topics.

Is CSRD mandatory?

Yes. CSRD is mandatory for companies that fall within its scope. Omnibus I narrowed that scope considerably, so fewer companies are now required to report, but for those that remain in scope, reporting and independent assurance are legal obligations.

When does CSRD take effect?

CSRD entered into force in 2023. Wave 1 companies are already reporting, with first reports published in 2025 for financial year 2024. Following the Omnibus I delay, the next group of large companies (Wave 2) will publish their first CSRD reports in 2028, covering financial year 2027.

How does CSRD compare to ISSB?

The main difference is materiality. CSRD applies double materiality, requiring disclosure of both a company’s impact on the world and sustainability’s effect on the company. The ISSB standards focus on financial materiality. The ESRS were designed to be highly interoperable with the ISSB standards.

Does CSRD apply to U.S. companies?

It can. A U.S. company is not subject to CSRD simply because it is American, but it can fall within scope if it generates significant net turnover in the EU and has an EU subsidiary or branch above defined size thresholds. Many U.S. multinationals are affected through their European operations.

What changed under the Omnibus I package?

Omnibus I, which entered into force on 18 March 2026, raised the scope thresholds to more than 1,000 employees and more than 450 million euros in turnover, removed listed SMEs from mandatory scope, delayed first reports for Wave 2 companies to 2028, simplified the ESRS, and introduced protections that limit data requests on smaller value chain companies. It did not repeal CSRD.

What is the difference between CSRD and ESRS?

CSRD is the law that establishes the obligation to report. The ESRS are the standards that specify what must be reported and how. CSRD sets the requirement and the ESRS provide the detailed rulebook companies follow to meet it.

Does CSRD require assurance of sustainability data?

Yes. CSRD requires that sustainability disclosures be independently assured, initially at a limited assurance level. This is a defining feature of the directive and is the main reason sustainability reporting has moved under board and audit-committee oversight.

RELATED ARTICLE: Mandi McReynolds, Chief Sustainability Officer At Workiva On Latest CSRD Regulation – ESG News

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