CSRD reporting requirements: a practical guide

2. Who is in scope?

Under the current directive (as amended by the 2025 "Omnibus" simplification package), CSRD applies to:

• Large EU undertakings exceeding two of: 250 employees, €50m turnover, €25m balance sheet.
• Listed SMEs on EU-regulated markets (with a lighter LSME standard).
• Non-EU parents with substantial EU turnover and an EU subsidiary or branch.

Micro-undertakings are excluded. Voluntary reporters can use the VSME standard as a proportionate entry point.

3. Reporting timelines

Waves have shifted following the Omnibus proposal, but the sequence remains: previously-NFRD companies first, then other large companies, then listed SMEs. Check the latest transposition in your Member State — dates diverge in practice.

4. The ESRS standards

Reporting follows the ESRS set:

• Cross-cutting: ESRS 1 (general requirements), ESRS 2 (general disclosures).
• Environmental: ESRS E1 Climate, E2 Pollution, E3 Water & marine, E4 Biodiversity, E5 Circular economy.
• Social: ESRS S1 Own workforce, S2 Value-chain workers, S3 Affected communities, S4 Consumers.
• Governance: ESRS G1 Business conduct.

Each topical standard defines disclosure requirements (DRs) and datapoints covering policies, actions, targets, and metrics.

5. Double materiality

CSRD introduces a double-materiality assessment (DMA): a topic is material if it is either impact-material (the company affects people or planet) or financially material(the topic affects the company's value). The DMA determines which ESRS topics — and datapoints — you must report.

A defensible DMA needs stakeholder input, a clear scoring methodology, and an audit trail from evidence to conclusion.

6. Datapoints and value chain

A full CSRD report can touch ~1,100 datapointsacross quantitative metrics, narrative disclosures, and policy/action/target descriptions. Roughly a third relate to thevalue chain — upstream suppliers and downstream users — which most companies cannot answer from their own systems alone.

Plan for two data streams:

• Internal: HR, finance, EHS, procurement, energy.
• External: supplier questionnaires, category-average factors, and estimation where primary data is not available.

7. Assurance and audit

CSRD requires limited assurance from day one, with a possible move to reasonable assurance later. Auditors will test: your DMA methodology, datapoint provenance, control environment, and consistency with financial statements.

8. How to prepare in 8 steps

1. Confirm scope and reporting year. Include all subsidiaries in the consolidation perimeter.
2. Run a double-materiality assessment. Document sources, stakeholders, thresholds.
3. Build the disclosure list. Map material topics to ESRS DRs and datapoints.
4. Assign owners. One accountable owner per datapoint, across HR, finance, EHS, procurement.
5. Collect data with an evidence trail. Files, formulas, and unit conversions must be reproducible.
6. Engage the value chain. Supplier surveys plus proxy factors for gaps.
7. Draft, review, and tag XBRL. ESEF requires digital tagging of the sustainability statement.
8. Assurance dry-run. Walk the auditor through the DMA and a sample of quantitative datapoints early.

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