Last updated: May 29, 2026. Indian companies should treat CSRD as both a direct-scope question and a customer-pressure question. The direct legal scope has changed significantly after the EU's stop-the-clock and Omnibus I amendments. Exporting to the EU does not, by itself, make an Indian company subject to full CSRD reporting. But Indian groups with substantial EU operations, EU subsidiaries or branches, EU-listed securities, or large EU customers may still need to prepare sustainability data, greenhouse gas calculations, and evidence that can support customer, lender, investor, or regulatory requests.
Short answer: Indian companies should first check whether they are directly in scope. Under the 2026 Omnibus I amendments, third-country reporting focuses on non-EU groups with significant EU turnover and a qualifying EU subsidiary or branch. Separately, many Indian exporters and suppliers may be indirectly affected because EU customers ask for emissions, labour, governance, and supplier due-diligence information for their own reporting, financing, or procurement needs. The practical response is not always a full ESRS report. Often it is a focused sustainability data pack built from BRSR, greenhouse gas calculations, policies, and customer-specific evidence.
Why CSRD still matters for Indian companies
The Corporate Sustainability Reporting Directive (CSRD) is an EU sustainability reporting framework, but its commercial effects are global. Indian companies can feel those effects through EU subsidiaries, EU branches, EU-listed securities, European customers, multinational procurement teams, lenders, investors, and global supply-chain requirements.
The key is to avoid two overreactions. One overreaction is to say every Indian exporter must prepare a full CSRD report. That is not correct. The other is to say Omnibus I removed the issue completely. That is also not correct. Many Indian companies will not be direct CSRD reporters, but they may still be asked for sustainability data by companies that are themselves reporting or financing against sustainability criteria.
Direct CSRD scope for Indian companies
Direct scope depends on the company's structure, EU presence, and thresholds. After Omnibus I, the main direct-scope questions for an Indian group are:
- Does the Indian parent or group generate more than EUR450 million net turnover in the EU for each of the relevant consecutive financial years?
- Does the group have a qualifying EU subsidiary or branch, with the updated rules referring to a subsidiary or branch turnover threshold above EUR200 million?
- Does the group have securities listed on an EU regulated market?
- Does an EU subsidiary itself meet the amended CSRD thresholds, including more than 1,000 employees and above EUR450 million net annual turnover?
- Which Member State law applies to the relevant EU entity, and has the Member State transposed the latest changes?
For many Indian companies, the answer will be no. That does not mean no action is needed. It means the company should move from a full-reporting assumption to a more proportionate readiness route.
Indirect CSRD pressure through customers and supply chains
Indian suppliers can still receive CSRD-related questions from EU customers even when the Indian supplier is not a direct CSRD reporter. These requests may ask for:
- Scope 1 and Scope 2 greenhouse gas emissions;
- relevant Scope 3 or product/service-level emissions data;
- energy use and renewable electricity information;
- human-rights, labour, health-and-safety, and grievance policies;
- supplier code of conduct or responsible sourcing evidence;
- water, waste, and pollution information where relevant;
- certifications, targets, transition actions, or climate-risk information; and
- methodology notes, assumptions, boundaries, and supporting documents.
Omnibus I introduces stronger protections intended to limit excessive trickle-down reporting burden for smaller value-chain undertakings. In practice, however, large customers may still ask for a concise set of sustainability data because they need to manage risk, respond to investors, meet procurement rules, or complete their own reporting.
How BRSR helps, and where it does not
India's Business Responsibility and Sustainability Reporting (BRSR) framework gives many Indian listed companies a useful starting point. SEBI requires the top listed entities to publish BRSR disclosures, and BRSR Core focuses on a smaller set of key ESG indicators. SEBI has also introduced and refined BRSR Core assessment or assurance, value-chain disclosures, and green-credit disclosure expectations.
BRSR can help because it already asks Indian companies to organize sustainability information around governance, environmental data, workforce issues, customer and community topics, responsible business conduct, and value-chain information. It can create a first layer of data discipline.
But BRSR is not the same as CSRD. CSRD and ESRS have their own reporting architecture, double materiality process, disclosure requirements, EU Taxonomy links, assurance expectations, and value-chain treatment. A BRSR report can therefore support a CSRD or customer response, but it should not be treated as a one-for-one substitute.
What Indian companies should check first
Before preparing a full CSRD-style report, Indian companies should complete a short applicability and exposure review:
- What EU revenue does the group generate, and through which entities?
- Does the group have EU subsidiaries, EU branches, or EU-listed securities?
- Do any EU subsidiaries independently meet the amended CSRD thresholds?
- Are any EU customers asking for sustainability data because of CSRD, EU Taxonomy, CSDDD, lender requirements, or procurement rules?
- Is the company already preparing BRSR or BRSR Core disclosures in India?
- Are value-chain partners or customers asking for GHG emissions, labour, human-rights, or governance data?
- Which data is already available, and which data would need new systems or evidence?
This review should decide the route: full CSRD readiness, EU subsidiary readiness, customer-request readiness, BRSR-to-customer mapping, or ongoing monitoring.
A practical response path for Indian suppliers
Most Indian companies indirectly affected by CSRD do not need to build a full ESRS report first. They need a structured data pack that can answer repeated customer and lender requests without starting from scratch each time.
A practical supplier data pack should include:
- company profile, sites, reporting boundary, and reporting period;
- Scope 1 and Scope 2 emissions calculations;
- selected Scope 3 categories where customers ask for value-chain emissions;
- energy, renewable electricity, fuel, travel, waste, and water data where relevant;
- health-and-safety, labour, human-rights, anti-corruption, and supplier policies;
- environmental permits, certifications, or management systems where available;
- targets, initiatives, and progress evidence;
- methodology notes and assumptions; and
- one version-controlled evidence folder that can support annual refreshes.
GHG calculations are usually the first pain point
Greenhouse gas emissions are often the first sustainability data point customers ask for because emissions roll into climate reporting, supplier scorecards, procurement decisions, and Scope 3 calculations. Indian companies should be ready to calculate at least Scope 1 and Scope 2 emissions, even if they are not preparing a full CSRD report.
A credible GHG calculation should define organizational boundaries, activity data sources, emission factors, location-based and market-based Scope 2 treatment where relevant, exclusions, assumptions, and data-quality limitations. If a customer asks for service-level or product-level emissions, the company may also need a narrower allocation methodology tied to that customer relationship.
Where Indian subsidiaries of EU companies fit
Indian subsidiaries of EU groups may be asked for data as part of the parent company's consolidated sustainability reporting. The Indian entity may not publish its own CSRD report, but it may need to provide data to the EU parent on emissions, employees, policies, incidents, risks, supplier practices, and local regulatory context.
This is often an internal reporting exercise rather than a public report. The Indian subsidiary should clarify the parent's data template, reporting boundary, material topics, evidence expectations, and deadlines. Where the parent is using ESRS, the Indian subsidiary may need to provide data in a format that maps to the parent's ESRS disclosures.
Common mistakes
The first mistake is treating CSRD as a direct legal obligation for every Indian exporter. Direct scope is narrower after Omnibus I and depends on EU structure and thresholds.
The second mistake is ignoring customer requests because the company is out of direct scope. Commercial exposure can still be real, especially for exporters, manufacturers, outsourced service providers, IT and business-process providers, logistics companies, and companies serving large EU groups.
The third mistake is assuming BRSR automatically solves CSRD. BRSR is useful, but it needs mapping and gap checks before it can support ESRS-style or customer-specific requests.
The fourth mistake is leaving emissions data too late. GHG calculations need energy, fuel, refrigerant, vehicle, travel, purchase, and sometimes product or service data. These are slow to reconstruct at year end.
What Indian companies should do now
A proportionate action plan looks like this:
- 1. Scope check: confirm direct CSRD exposure based on EU turnover, subsidiaries, branches, listings, and Member State law.
- 2. Customer exposure check: identify EU customers, multinational customers, lenders, investors, and tenders likely to ask for sustainability data.
- 3. BRSR mapping: compare existing BRSR/BRSR Core disclosures against likely customer or ESRS data requests.
- 4. GHG baseline: calculate Scope 1 and Scope 2 emissions, then identify relevant Scope 3 or service-level requests.
- 5. Evidence pack: organize policies, calculations, invoices, activity data, certifications, and methodology notes.
- 6. Response templates: prepare standard answers for common customer questionnaires.
- 7. Annual refresh: update data and evidence each year rather than rebuilding from scratch.
How Keslio can help
Keslio helps companies respond proportionately to CSRD-related expectations without turning every request into a full ESG project. For Indian companies and suppliers, we can support:
- CSRD direct-scope and customer-exposure checks;
- BRSR-to-customer-request mapping;
- EU customer sustainability questionnaire support;
- Scope 1, Scope 2, and relevant Scope 3 GHG emissions calculations;
- service-level or customer-specific emissions calculations where required;
- supplier evidence packs and data request templates;
- supplier request support for customer sustainability requirements;
- sustainability reporting and communications support; and
- annual refreshes for recurring customer or parent-company requests.
Official sources and further reading
- European Commission: Corporate sustainability reporting
- Directive (EU) 2026/470: Omnibus I amendments to CSRD and CSDDD
- Council of the EU: CSRD and CSDDD simplification
- SEBI: BRSR Core framework for assurance and ESG disclosures for value chain
- SEBI: Measures on assurance or assessment, value-chain ESG disclosures, and green credits
Conclusion
CSRD still matters for Indian companies, but the right response is now more nuanced. Some Indian groups may be directly in scope because of EU turnover, EU subsidiaries or branches, EU-listed securities, or EU entity thresholds. Many more will be indirectly affected through customer, parent-company, lender, investor, or procurement requests.
The best first step is to check the route, then build the right level of sustainability data. For many Indian companies, that means using BRSR where available, preparing reliable GHG calculations, and keeping an evidence-backed data pack that can answer customer requests without overbuilding a full CSRD report.
