The CSRD sets out sustainability disclosure requirements for certain companies in the European Union. Its goal is to improve transparency regarding their environmental and social impacts, as well as the sustainability risks and opportunities that affect their business.
To determine how this affects your company, you must identify whether it is required to report, starting in which fiscal year, and what requirements it must meet. This assessment is particularly important following the 2026 reform, which has narrowed the scope of the regulations.
In this article, you'll find the key points of the CSRD and practical steps for organizing your company's sustainability information.
What is the CSRD Directive?
CS RD stands for the Corporate Sustainability Reporting Directive.
The applicable regulation is Directive (EU) 2022/2464. Covered companies must include sustainability information in a specific section of their management report and have it verified.
This requires organizing data, assigning responsibilities, and retaining records that make it possible to explain and review the published information.
Why was the CSRD introduced, and how does it differ from the NFRD?
The Corporate Sustainability Reporting Directive (CSRD) builds upon the previous non-financial reporting framework, known as the NFRD, to improve the quality and comparability of corporate information.
| Appearance | Change Introduced by the CSRD |
| Common Standards | It establishes European standards for financial reporting. |
| Dual Materiality | Consider the company's impacts and the financial effects of sustainability. |
| Management Report | Incorporate sustainability information into corporate reporting. |
| Verification | It requires an opinion based on a limited review engagement. |
The CSRD initially expanded the number of companies subject to its requirements. However, the 2026 reform has narrowed that scope, so the initial estimates of approximately 50,000 affected companies should not be presented as a current figure.
Which companies are affected by the CSRD?
The new European scope focuses on companies that have both an average of more than 1,000 employees and annual net revenue of more than 450 million euros. It also includes parent companies of groups that meet both criteria on a consolidated basis.
Companies and groups in the European Union
Directive (EU) 2026/470 amends the scope of application. To determine the obligation, the thresholds, the scope of the group, the exemptions, and national regulations must be reviewed.
Therefore, the criterion in the draft—meeting two of three thresholds (number of employees, revenue, and assets)—does not reflect the newly approved scope.
Publicly Traded Companies and SMEs
The reform eliminates the mandatory reporting requirement for publicly traded SMEs. Being publicly traded, in and of itself, does not trigger a reporting obligation under the new framework.
Companies from third countries
The specific regime applies to companies from third countries with a net turnover in the EU of more than 450 million euros in each of the last two consecutive fiscal years, and a subsidiary or branch that meets the legal requirements, including the threshold of more than 200 million euros in the previous fiscal year.
Application in Spain
This specific requirement must be compared with current Spanish law. The deadline for transposing the amendments regarding corporate disclosure and verification is March 19, 2027.
CSRD Implementation Timeline
The timeline should be interpreted in conjunction with Directive (EU) 2025/794, known as “stop the clock, ” and the 2026 reform.
The fiscal year covered by this report and the year of publication are different dates. For fiscal years that coincide with the calendar year:
| Group | Reference Exercise | Regular publication |
| First wave of companies, initially subject to the NFRD and falling under the first tier of the CSRD (listed companies or financial institutions with more than 500 employees that were already reporting under the previous regulations) | Starting in 2024 | Starting in 2025 |
| Other companies and groups included in the new scope (Companies with more than 1,000 employees and more than 450 M€ in net revenue ) | Starting in 2027 | Starting in 2028 |
| Third-country companies subject to the specific regime (non-EU groups with consolidated revenue in Europe exceeding 450 M€.) | Starting in 2028 | Starting in 2029 |
| Listed SMEs | The planned mandatory inclusion has been eliminated | It is not applicable under that system |
These dates should be applied in accordance with national legislation and the circumstances of each entity. boe.es
Member States may grant exemptions for the 2025 and 2026 fiscal years to certain companies in the first wave that fall outside the scope. The exemption should not be considered granted without first verifying national regulations.
What does the CSRD require?
Dual Materiality
Dual materiality analyzes two dimensions:
- Impact Materiality: How the Company Affects People and the Environment.
- Financial Materiality: How Sustainability Issues Can Affect Your Financial Position and Outlook.
An issue may be material in terms of either of these dimensions or both.
For example, an industrial facility may have an impact due to its water consumption and, at the same time, face economic risks due to supply constraints.
Environmental, Social, and Governance Information
European standards cover issues such as climate change, biodiversity, workers, and corporate conduct.
The information to be disclosed depends on the general requirements and the materiality analysis. It does not mean filling out all the indicators without assessing their applicability.
Data Traceability and Control
To prepare the report, it is advisable to document the following:
- The source of each piece of data and the person responsible for it.
- Calculation Methods and Estimates.
- The inspections and checks that were conducted.
- The evidence supporting the results.
This organization facilitates the preparation of the report and the handling of the verifier's requests.
Limited Audit
Mandatory information is subject to limited verification. The reform eliminates the requirement to adopt European standards for reasonable verification; this development should not be presented as a future obligation that has already been established.
ESRS: European Sustainability Standards
The ESRS, known as NEIS in the Spanish version, establish the requirements for preparing sustainability information.
Delegated Regulation (EU) 2023/2772 sets forth the first set of these rules, including general requirements and thematic standards.
EFRAG provides technical advice, and the European Commission adopts the standards through delegated acts.
The Commission adopted a revision of the ESRS on July 3, 2026. For each report, the version applicable to the fiscal year must be verified: the adoption of the act and its entry into force are two different events. According to the official information consulted, its entry into force requires publication in the Official Journal.
How to Prepare Your Company to Comply with the CSRD
Adaptation requires coordination among the finance, sustainability, operations, human resources, and management departments.
1. Confirm the obligation and the schedule
Review employees, revenue, group structure, and potential exemptions. Document the scope and the first year of application.
2. Analyze information gaps
Compare the available data with the applicable requirements. Identify what information is missing and which processes need improvement.
3. Assess dual materiality
Identify impacts, risks, and opportunities. Document the criteria used, the areas involved, and the conclusions.
4. Define metrics and assign responsibilities
Assign a data source, a calculation method, a frequency, and a person in charge to each indicator.
5. Implement quality controls
Verify the integrity of the data and the consistency among sustainability, financial, and operational information.
6. Organize the evidence for verification
Keep records, calculations, and supporting documentation. Plan the review in advance to resolve issues before publishing.
This sequence is a practical organizational framework that should be adapted to the specific activities and complexity of each company.
How ACERTA Can Help You with Climate Data for Your Company
The reliability of environmental data is important for preparing sustainability reports. In this area, ACERTA offers independent verification of the carbon footprints of companies and organizations.
Our carbon footprint verification service reviews data, calculations, emission sources, methodology, and evidence supporting the reported emissions.
Do you need to improve the reliability of your emissions data? Check out the ACERTA’s carbon footprint verification service and request information on the appropriate scope for your organization.
Questions Frequently Asked Questions
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It stands for Corporate Sustainability Reporting Directive: the European directive on corporate sustainability reporting.
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No. The thresholds under the new framework, the rules for groups, the exemptions, and the applicable national legislation must be evaluated.
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Yes. Being exempt from the requirement to publish a CSRD report does not prevent a company from receiving requests from clients or financial institutions. The voluntary framework is intended to facilitate proportionate responses.
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The CSRD establishes the legal framework for disclosure requirements. The ESRS specify the requirements for preparing the disclosures.
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No. Carbon footprint verification is a specific review of the calculations related to GHG emissions, whereas CSRD verification is much broader and assesses the reliability of the organization’s entire sustainability report, including environmental, social, and governance (ESG) aspects.