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The draft CSRD presented by the EU Commission in April 2021 profoundly changes the scope and nature of sustainability reporting by companies.

The CSRD significantly expands existing rules on non-financial reporting. All companies listed on an EU-regulated market (with the exception of micro-enterprises) are covered by the new reporting obligation. In addition, all non-capital market oriented companies are covered by the CSRD if they fulfil two of the following three criteria:

  • Balance sheet total > 20 million euros
  • Net sales > 40 million euros
  • Number of employees > 250

It is estimated that this would affect about 50,000 companies in the EU, 15,000 of them in Germany alone. 

The new CSR Directive follows a double materiality perspective. This means that companies must record the effect of sustainability aspects on the economic situation of the company. And they must clarify the impact of operations on sustainability aspects. The CSRD requires reporting to include information on:

  • Sustainability goals,
  • the role of the executive board and the supervisory board
  • the company's most significant adverse impacts, and
  • intangible resources not yet accounted for.

In addition, with the new CSRD there is no longer the possibility to publish non-financial information in a separate non-financial report. In future, sustainability information is to be disclosed exclusively in the management report. 

Overview of the main changes

    Current EU Directive
Corporate Sustainability Reporting Directive
calendar icon Which companies are affected?

Large companies (>500 employees) of public interest (listed companies, banks and insurance companies)

Companies that meet two of the following three criteria:

  • > 250 employees
  • > 40 Mill. € Turnover
  • > 20 Mill. € Balance sheet total

Listed companies

building icon How many companies are affected?

Circa 12,000

Circa 50,000 (15,000 in Germany alone)

graph icon What is the scope of the reporting obligations?

Companies should report on:

  • Environmental protection
  • Social responsibility and treatment of employees
  • Anti-corruption and bribery
  • Diversity on company boards

Additional reporting obligation on

  • „Double Materiality
  • Other forward-looking information, including targets and progress
  • Information on intangible assets
  • Reporting in accordance with the Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy Regulation
target icon Where should companies report?

In the annual report (also possible separately)

Exclusively in the management report

book icon From when?

FY 2018

  • for companies subject to NFRD: FY 2024
  • for all large non-NFRD obligated companies: FY 2025

Learn more in our brochure (in German only)