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Compliance · The complete guide

CSRD / ESRS Reporting

In short

The Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464) replaces the NFRD and dramatically expands EU sustainability disclosure. Reports are prepared per the European Sustainability Reporting Standards (ESRS), assured by a statutory auditor, tagged in XBRL inside the management report, and phased in starting FY 2024 for large public-interest entities.

Read the full summary

The 'Omnibus' simplification package proposed in 2025 has revised the scope and timetable for waves 2-4.

2,700 words · ~13 min read
On this page
  1. 01What CSRD is
  2. 02Scope and the four waves (pre-Omnibus)
  3. 03The 2025 Omnibus simplification
  4. 04ESRS — the standards themselves
  5. 05Double materiality
  6. 06The value-chain horizon
  7. 07Assurance and digital tagging
  8. 08Interlock with other EU regimes
  9. 09How V5 supports CSRD reporting
  10. 10Common pitfalls
On this page · 10 sections
  1. 1What CSRD is
  2. 2Scope and the four waves (pre-Omnibus)
  3. 3The 2025 Omnibus simplification
  4. 4ESRS — the standards themselves
  5. 5Double materiality
  6. 6The value-chain horizon
  7. 7Assurance and digital tagging
  8. 8Interlock with other EU regimes
  9. 9How V5 supports CSRD reporting
  10. 10Common pitfalls
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01What CSRD is

CSRD is the EU directive that requires undertakings in scope to report on sustainability matters following mandatory European Sustainability Reporting Standards. It replaces the Non-Financial Reporting Directive (NFRD), expands the scope by an order of magnitude, raises the assurance bar from voluntary to limited (then eventually reasonable), and integrates the disclosures into the management report so investors and lenders read them alongside financial statements.

The directive entered into force 5 January 2023 and was to be transposed by Member States by 6 July 2024. Transposition has been uneven — some states transposed on time, others slipped to late 2024 or early 2025.

02Scope and the four waves (pre-Omnibus)

WaveFY first reportedWho
1FY 2024 (reports in 2025)Large undertakings already in NFRD scope (≈11,000 entities)
2FY 2025 (reports in 2026)Other large undertakings (≈50,000 entities)
3FY 2026 (reports in 2027)Listed SMEs (with opt-out to FY 2028)
4FY 2028 (reports in 2029)Non-EU parent groups with significant EU turnover

An undertaking is 'large' if it exceeds two of three thresholds: €50m net turnover, €25m balance sheet, 250 employees (thresholds revised by Delegated Directive 2023/2775).

03The 2025 Omnibus simplification

In February 2025 the Commission proposed the Omnibus I package, which (subject to co-decision) raises the CSRD scope threshold to 1,000 employees, defers Wave 2 and 3 application by two years, and trims the ESRS data points. The package is in legislative process through 2025-2026; until it is adopted, the existing thresholds and dates remain operative. Operators should track the trilogue outcomes carefully and not yet rely on the relaxed thresholds.

Wave 1 is unchanged

The Omnibus does not defer Wave 1. Entities already in NFRD scope are reporting on FY 2024 in 2025 — that obligation is live.

04ESRS — the standards themselves

ESRS Set 1 was adopted by Commission Delegated Regulation 2023/2772 in July 2023 and comprises 12 standards: two cross-cutting (ESRS 1 General Requirements, ESRS 2 General Disclosures) and ten topical: E1 Climate, E2 Pollution, E3 Water & Marine, E4 Biodiversity, E5 Resource Use & Circular Economy, S1 Own Workforce, S2 Value-Chain Workers, S3 Affected Communities, S4 Consumers, and G1 Business Conduct.

Topical standards are subject to a double materiality assessment — disclose only if material to the undertaking either from an impact-on-people-and-planet view (impact materiality) or from a financial-effects-on-the-undertaking view (financial materiality). ESRS 2 General Disclosures and parts of ESRS E1 Climate are mandatory regardless of materiality.

05Double materiality

Double materiality is the central methodological commitment of CSRD. The undertaking must assess each sustainability matter from two perspectives — impact and financial — and disclose where either is material. The assessment process itself must be disclosed: who was consulted, what evidence was used, what thresholds were applied. Auditors test the process, not just the conclusion.

06The value-chain horizon

ESRS disclosures extend across the value chain — upstream suppliers and downstream customers — for impact assessment and for many specific disclosures (Scope 3 GHG, value-chain workers under S2, raw material origins under E5). This is the practical hardest part: the entity must collect data it does not own, from counterparties that have no contractual obligation to provide it. The first-year transition allowed estimates and reduced value-chain disclosures; that relief tapers over the first three reporting cycles.

07Assurance and digital tagging

Sustainability information must be assured by a statutory auditor (or independent assurance services provider authorised by the Member State). The initial standard is limited assurance; the Commission will assess feasibility of moving to reasonable assurance by 2028.

The disclosures must be tagged in XBRL using the ESRS taxonomy and embedded in the management report — the same machine-readable format that already governs the financial statements (ESEF). Tagging is not optional; preparers need a vendor or in-house tagging tool aligned to the published taxonomy.

08Interlock with other EU regimes

  • EU Taxonomy (Regulation 2020/852) — eligibility and alignment KPIs feed E1 Climate and ESRS 2.
  • CSDDD (Directive 2024/1760) — due-diligence outcomes are disclosed under CSRD; CSDDD is the operational obligation, CSRD is the disclosure layer.
  • EUDR (Regulation 2023/1115) — deforestation-free supply-chain data feeds E4 Biodiversity / S3 Affected Communities.
  • EU Pay Transparency Directive — pay-gap data feeds S1 Own Workforce.
  • CBAM — embedded-emissions data feeds Scope 3 Category 1 under E1.

09How V5 supports CSRD reporting

CSRD in V5

V5 captures operational data that CSRD consumes — environmental monitoring, energy and water use, waste flows, workforce records, supplier qualifications, EUDR DDS data, product-quality and complaint records — as native records with provenance and audit trail. Period-end reporting extracts produce the source data for ESRS data points; the double-materiality assessment is itself a controlled record with evidence and stakeholder consultation traceability. V5 does not produce the final tagged report but supplies the operational evidence base the report depends on.

10Common pitfalls

  • Skipping the double-materiality process and disclosing everything 'just in case' — auditors will challenge an assessment that did not actually assess.
  • Treating CSRD as a comms/marketing exercise rather than an auditable financial-report annex.
  • Underestimating data lineage — every disclosed metric needs an evidenced source.
  • Assuming Omnibus simplification will save you — it has not yet adopted.
  • Value-chain data gathered ad-hoc rather than built into supplier contracts and onboarding.
  • Late selection of XBRL tagging tool — taxonomy evolves and integration is non-trivial.

Frequently asked questions

Q.Is CSRD mandatory for non-EU companies?+

Wave 4 brings non-EU parent groups into scope where they have significant EU turnover (€150m EU + at least one large EU subsidiary or branch) — reporting starting FY 2028.

Q.Can the CSRD report be separate from the financial statements?+

No. CSRD requires sustainability information in a dedicated section of the management report — not a separate sustainability report. The legal anchor is the management report.

Q.Is limited assurance the final state?+

The directive starts at limited assurance and contemplates a move to reasonable assurance once the Commission completes a feasibility assessment, no earlier than 2028.

Q.What happens if the Omnibus passes mid-reporting cycle?+

Operators in scope under current law remain in scope until the Omnibus is adopted and transposed. Plan to the current rules; track the trilogue; do not bet on simplification arriving in time.

Primary sources

  • Directive (EU) 2022/2464 — Corporate Sustainability Reporting Directive
  • Commission Delegated Regulation 2023/2772 — first set of ESRS
  • EFRAG — European Sustainability Reporting Standards
  • EU Omnibus I Simplification Package (February 2025)

Further reading

  • EU CSDDD
    Paired due-diligence directive — same value chain, different lens.
  • EUDR
    Operational obligation often consumed by CSRD value-chain disclosures.
  • EU MDR
    Quality and PMS records often feed CSRD product-related metrics.
Talk to us about CSRD / ESRS Reporting

Want to see how CSRD / ESRS Reporting could fit into your own records and workflows? Explore the related V5 pages or talk to our team about what applies to your operation.

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Inside V5
  • → Score your compliance gap — then download the validation pack.
  • → Document control — one version in force, every change signed and explained.
  • → QMS — quality records next to the work they concern.
Related terms
  • → EU CSDDD / CS3D (2024)
  • → Audit management
  • → Management review

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