Implementing CSRD Reporting Digitally and in Compliance

Status: June 2025

Yes, however, in February 2025, the European Commission proposed significant amendments to the Corporate Sustainability Reporting Directive (CSRD) through the so-called Omnibus Directive. These changes aim to narrow the scope of reporting obligations and partially postpone their implementation.

Who is affected?

If the criteria proposed under the Omnibus procedure are adopted, the reporting obligation would apply only to large companies that:

• have more than 1,000 employees and …
• either generate net revenue exceeding EUR 50 million or hold total assets above EUR 25 million.

This adjustment would reduce the number of companies required to report by approximately 80%.

Postponement of reporting obligations:

• „Wave 1“ Companies: Listed companies with more than 500 employees that were already subject to reporting requirements under the German CSR Directive Implementation Act (CSR-RUG) must still report for the 2024 financial year.
• „Wave 2“ Companies: Other large companies that were initially expected to report as of 2025 will now benefit from a two-year deferral and will only be required to report in 2028 for the 2027 financial year.
• „Wave 3“ Companies: Listed SMEs will be required to report from 2029 for the 2028 financial year; however, the reporting obligation for these companies may be waived entirely.

Further changes:

• Non-EU companies: Enterprises headquartered outside the EU will only be subject to the reporting obligation if they generate more than EUR 450 million in revenue within the EU or if they own an EU-based subsidiary with revenue exceeding EUR 50 million.

The proposed amendments aim to reduce the administrative burden on companies and enhance the efficiency of sustainability reporting.

Status: June 2025

The Corporate Sustainability Reporting Directive (CSRD) will be implemented later than originally planned for many companies, following the adoption of the “Stop-the-Clock” Directive in April 2025. A final decision regarding the remaining proposed amendments is not expected before 2026.

2025:

• „Wave 1“ Companies:
  Listed companies with more than 500 employees that are already subject to the Non-Financial Reporting Directive (NFRD) or the German CSR Directive Implementation Act (CSR-RUG) must report for the first time in 2025, covering the 2024 financial year in accordance with the new CSRD requirements.

2028:

• „Wave 2“ Companies:
  Large companies that meet the proposed new CSRD thresholds (more than 1,000 employees and either more than EUR 50 million in revenue or more than EUR 25 million in total assets) will be required to report as of January 1, 2028.
• Listed Small and Medium-Sized Enterprises (SMEs):
  These companies have been granted a deferral until 2029 and may be exempted from the CSRD reporting obligation altogether.
• Non-EU Companies:
  Companies headquartered outside the EU will only be subject to CSRD requirements if they generate more than EUR 450 million in revenue within the EU or own an EU-based subsidiary with revenue exceeding EUR 50 million.

This phased implementation gives companies the opportunity to gradually prepare for the new reporting obligations and ensure that the necessary systems and processes are in place.

Status: June 2025

The Corporate Sustainability Reporting Directive (CSRD) requires companies to report comprehensively on their sustainability performance. The Omnibus proposal introduced in February 2025 aims to reduce the scope of reporting obligations and simplify certain requirements. Nonetheless, key areas of disclosure remain mandatory for companies and must be covered in their sustainability reports:

Environmental Aspects:

• The company’s impacts on the environment and climate
• Climate change mitigation and adaptation strategies
• Energy consumption and efficiency
• Use of water resources
• Waste management

Social and Employee Matters:

• Measures to promote gender equality
• Working conditions, including health and occupational safety
• Employee rights and social dialogue
• Compliance with labor standards and human rights across the supply chain
• Diversity and inclusion in the workplace

Governance and Corporate Management:

• Corporate governance and supervisory structures
• Business ethics and corporate integrity
• Anti-corruption and anti-bribery measures
• Internal control and risk management systems
• Independence and qualifications of management and supervisory board

Economic Sustainability:

• Business model and corporate strategy with regard to sustainability
• Sustainability-related risks and opportunities
• Sustainability targets and progress towards achieving them
• Impact of sustainability factors on financial performance and corporate strategy

Data and Performance Indicators:

• Quantitative and qualitative KPIs for measuring sustainability performance
• Comparable and consistent data to assess progress over time
• Targets and benchmarks

Supply Chain and Business Partners:

• Sustainability practices across the entire supply chain
• Monitoring and evaluation of suppliers with regard to social and environmental standards
• Collaboration with suppliers and partners to improve sustainability performance

Reporting Standards and Transparency:

• Application of recognised reporting standards such as the European Sustainability Reporting Standards (ESRS)
• Ensuring transparency and accessibility of reports for all relevant stakeholders
• External assurance and verification of sustainability disclosures

The first Omnibus package proposes a 25% reduction in the number of required data points and a suspension of additional sector-specific standards in order to ease the reporting burden on companies. Nevertheless, the core objective of the CSRD remains unchanged: to meet the increasing demands of investors, customers, and the public through transparent and credible sustainability reporting.