What is the Corporate Sustainability Reporting Directive (CSRD)?
The CSRD is Directive (EU) 2022/2464. It added sustainability-reporting duties to the EU Accounting Directive. If your company or group is in scope, Articles 19a and 29a require a dedicated sustainability statement in the management report using ESRS. The statement covers material impacts on people and the environment and material financial risks and opportunities.
Directive (EU) 2026/470 changed scope and timing. From financial years starting on or after 1 January 2027, Articles 19a(1) and 29a(1) require more than 1,000 employees and net turnover above EUR 450 million, consolidated for groups. Check the Germany reporting guide against the national law that applies to your reporting year.
Why does the CSRD matter to you?
If your company crosses both Article 19a thresholds, or your group crosses both Article 29a thresholds, its management report needs the sustainability statement. Article 34(1)(aa) requires a limited-assurance opinion, so unsupported numbers, missing methods, or an undocumented materiality decision can delay sign-off.
Article 19a(3) also covers upstream and downstream value-chain information. A reporting customer may need your site energy, metric tonnes of CO2e, workforce data, pollution controls, or product inputs. After the 2026 amendments enter national law, a supplier or other value-chain company with no more than 1,000 employees can decline a CSRD reporting request that asks for more than the EU voluntary standard.
How does the CSRD work?
- Confirm scope and year: test the entity and group against Articles 19a(1), 29a(1), and 40a(1), then record the financial year and national law.
- Assess double materiality: ESRS 1 requires you to identify material impacts on people or the environment and material financial risks or opportunities for the undertaking.
- Prepare disclosures: Article 19a(2) covers the business model, targets, governance, policies, actions, due diligence, impacts, risks, opportunities, and indicators. The ESRS currently in force use E1-6 for gross Scope 1, Scope 2, Scope 3, and total GHG emissions in metric tonnes of CO2e. The Commission's 3 July 2026 revised ESRS act was not yet in force on 19 August 2026; its adopted text renumbers this disclosure as E1-8 for financial years from 2027.
- Publish and support assurance: put the statement in the management report, retain source records, and prepare the Article 34(1)(aa) limited-assurance file.
What mistakes should you avoid?
- Using the old 250-employee, EUR 40 million turnover, or EUR 20 million balance-sheet tests after Directive (EU) 2026/470 changed scope.
- Assuming a supplier questionnaire means your company must prepare a complete ESRS sustainability statement.
- Reporting only climate data when Article 19a(2) and the materiality assessment identify material social, environmental, or governance matters.
- Sending figures without the reporting period, organisational boundary, unit, calculation method, source record, and approval owner needed for limited assurance.
Does the CSRD apply to non-EU companies?
Yes, if the EU subsidiary or branch and its non-EU parent cross the Article 40a thresholds. From financial years starting on or after 1 January 2028, the EU subsidiary or branch can have to publish the parent's group report. The parent must exceed EUR 450 million in EU net turnover in each of two financial years, and the subsidiary or branch must exceed EUR 200 million in the preceding year.
What can a customer ask a supplier for under the CSRD?
Ask for the exact ESRS requirement, entity, site, product, metric, unit, and period. Article 19a(3) permits requests needed for material value-chain disclosures. If you have no more than 1,000 employees, test the request against the voluntary-standard cap before accepting a full ESRS dataset.
Is the CSRD the same as ESRS?
No. The CSRD and the amended Accounting Directive determine scope, placement, publication, and assurance. Commission Delegated Regulation (EU) 2023/2772 contains ESRS, which specify the information an in-scope reporter discloses. Record the ESRS version and any transitional relief used for the financial year.