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CSRD explained: obligations, deadlines, implementation

The CSRD requires assured sustainability reporting. After Omnibus I the scope is two-stage: through financial year 2026 as before, and from 2027 only above 1,000 employees and EUR 450m turnover.

CSRD at a glance

What?

An EU directive on mandatory, externally assured sustainability reporting. It replaces the earlier NFRD and is part of the European Green Deal.

Who reports through financial year 2026?

Public-interest entities with more than 500 employees keep reporting as before.

And from financial year 2027?

Only companies with more than 1,000 employees and more than EUR 450m net turnover — both criteria at once. Listed SMEs are no longer obliged.

How?

Reporting under the ESRS inside the management report, externally assured at the limited level. The digital tagging duty is currently suspended.

Frequently asked questions about the CSRD

That depends on the financial year. Through financial year 2026, public-interest entities with more than 500 employees report. From financial year 2027, only companies with more than 1,000 employees and more than EUR 450m turnover are covered, and both criteria must be met at once.

Not for CSRD scope. Balance sheet, turnover and headcount in the two-of-three logic still define what a "large undertaking" is under the Accounting Directive. The CSRD threshold from financial year 2027 is independent of that and requires both criteria at the same time.

The CSRD is the directive and governs the "whether" and "who". The ESRS are the standards and govern the "what" and "how".

No. Listed SMEs were originally planned as the third wave but fell out of scope entirely with Omnibus I. Smaller companies can report voluntarily under the Voluntary Standard (Delegated Regulation (EU) 2026/1560). Its advantage is a binding cap: a CSRD-reporting customer may request only that standard's datapoints from companies with up to 1,000 employees.

Yes, externally and at the limited assurance level. The planned move to reasonable assurance was dropped. The Commission only assesses whether it will adopt such standards.

Not at present. Omnibus I suspended the mark-up duty in Article 29d until the ESEF regulation (EU) 2019/815 is updated, and no application date exists. EFRAG put a draft taxonomy out for consultation in September 2026. Building machine-readable data structures is sensible, but there is no deadline for it.

In the company's management report, as a dedicated sustainability statement. The Taxonomy disclosures under Article 8 of the Taxonomy Regulation belong in the same statement but are not subject to the ESRS.

The obligation ends, the data requests do not. Large customers, banks and investors ask for ESG data regardless of who is legally obliged, and you need a GHG inventory anyway for CBAM or product footprints. The difference is that you can answer voluntarily and in a structured way instead of under pressure.

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