CSRD compliance is mandatory.
The stress isn’t.

As of June 2025

Yes, however, in February 2025 the European Commission proposed significant changes to the **Corporate Sustainability Reporting Directive (CSRD)** through the so-called **Omnibus Directive** — changes that would narrow the scope of companies subject to reporting obligations and partially delay the introduction of those obligations.

Who is affected?

If the criteria proposed in the Omnibus process come into effect, the reporting obligation would apply only to large companies that:

• have more than 1,000 employees and …
• either have a net turnover exceeding 50 million euros or a balance sheet total exceeding 25 million euros.

This change would reduce the number of companies required to report by around 80%.

Postponement of reporting obligations:

Wave 3 companies: Listed SMEs will not be required to report until 2029, covering the financial year 2028 — and the reporting obligation for these companies may be dropped entirely.

Wave 1 companies: Listed companies with more than 500 employees that were already subject to reporting obligations under the CSR Directive Implementation Act (CSR-RUG) must continue to report from the financial year 2024 onwards.

Wave 2 companies: Other large companies that were previously required to report from 2025 onwards have been granted a two-year extension and must now report for the first time in 2028, covering the financial year 2027.

As of June 2025

Under the “Stop-the-clock” directive adopted in April 2025, the **Corporate Sustainability Reporting Directive (CSRD)** will be introduced later than originally planned for many companies. **A final decision on the further proposed changes 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 CSR Directive Implementation Act (CSR-RUG) must report for the first time in 2025, covering the financial year 2024, in accordance with the new CSRD requirements.

2028:

• Wave 2 companies:
  Large companies that meet the proposed new CSRD criteria (more than 1,000 employees and either more than 50 million euros in revenue or more than 25 million euros in total assets) must report from 1 January 2028 onwards.
• 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 entirely.
• Non-European companies:
  Companies headquartered outside the EU will only be subject to reporting obligations if they generate more than 450 million euros in revenue within the EU or own an EU subsidiary with revenue exceeding 50 million euros.

This phased introduction enables companies to prepare for the new reporting requirements step by step and to ensure that they can implement the necessary systems and processes.

As of June 2025

The **Corporate Sustainability Reporting Directive (CSRD)** requires companies to report comprehensively on their sustainability performance. The **Omnibus process** proposed in February 2025 aims to reduce the scope of these reporting obligations and simplify the requirements. Nevertheless, key reporting areas remain that companies must cover:

Environmental considerations:

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

Social and employment aspects:

• Measures to promote gender equality
• Working conditions, including health and safety at work
• Workers’ rights and social dialogue
• Compliance with labour standards and human rights throughout the supply chain
• Diversity and inclusion in the workplace

Governance and management:

• The company’s management and supervisory structure
• Business ethics and integrity
• Combating corruption and bribery
• Internal control and risk management systems
• Independence and qualifications of the members of the Executive Board and the Supervisory Board

Economic sustainability:

• Business model and corporate strategy with regard to sustainability
• Opportunities and risks associated with sustainability
• Sustainability goals and progress towards achieving them
• The impact of sustainability factors on financial performance and corporate strategy

Data and performance indicators:

• Quantitative and qualitative performance indicators for measuring sustainability performance
• Comparable and consistent data for assessing progress over time
• Targets and benchmarks

Supply chain and business partners:

• Sustainability practices throughout the entire supply chain
• Assessment and monitoring of suppliers with regard to social and environmental standards
• Collaboration with suppliers and business partners to improve sustainability performance

Reporting standards and transparency:

• The use of recognised reporting standards such as the **European Sustainability Reporting Standards (ESRS)**​
• Ensuring that reports are transparent and accessible to all relevant stakeholders
• External audit and verification of sustainability reports

The first **Omnibus package** proposes reducing the number of required data points by 25% and dropping the introduction 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 growing expectations of investors, customers, and the public through transparent and traceable reporting.