CSRD Reporting Requirements
CSRD reporting requirements: the key facts at a glance
The CSRD reporting requirements apply to companies with more than 1,000 employees and net turnover of more than EUR 450 million. Both thresholds must be exceeded. Reports follow the European Sustainability Reporting Standards (ESRS) and are subject to external assurance.
- Timeline: Reporting is mandatory from financial year 2027, with the first report published in 2028.
- Germany: The German CSRD Implementation Act has not yet been passed. Until then, capital-market-oriented companies, credit institutions, and insurers with more than 500 employees prepare the non-financial statement under Sections 289b et seq. of the German Commercial Code (HGB), introduced by the CSR Directive Implementation Act (CSR-RUG).
- Below the thresholds: There is no reporting obligation, but data requests from customers continue.
Further details and special cases are covered in the FAQ.
Double materiality assessment: the foundation of the CSRD report
The double materiality assessment is a requirement of the ESRS and the foundation of every CSRD report. It determines which topics are material for a company. The framework consists of the ten ESRS topics, from climate change to business conduct, each with several sub-topics. For climate change, these are climate change mitigation, climate change adaptation, and energy; for own workforce, they include working conditions, health and safety, and diversity and equal treatment.
For each sub-topic, the assessment examines where it applies: within the company itself or in the upstream or downstream value chain. It also examines whether it represents a risk or an opportunity. Each topic is assessed from two perspectives, hence the name “double materiality assessment”:
- Impact perspective: How does the company affect people and the environment?
- Financial perspective: How does the topic affect business, earnings, and financing?
A topic is material if it exceeds the thresholds previously set by the company from at least one of the two perspectives.
For reading up and orientation: The following resources explain terms and approach. Applying them within the company remains project work.
- EFRAG Knowledge Hub: implementation guidance on the materiality assessment
- Infozentrum UmweltWirtschaft Bavaria: double materiality assessment with the guide “10 steps to the CSRD” (in German)
The CSRD report: content and structure
One aim of the CSRD is to make sustainability information as comparable and transparent as financial information and to give it similar weight. Large capital-market-oriented companies therefore already integrate their CSRD report as a separate section into the management report, which is part of the annual report, for example as a “sustainability statement”. The EU directive provides for this section in the management report. Under current German law, a separate publication is also possible.
Reporting under the CSRD follows a clear structure:
- General disclosures: basis of preparation, governance, strategy, and business model
- Materiality assessment: process and results, meaning the material impacts, risks, and opportunities
- Environmental, social, and governance information: only on the material topics. Each section describes policies, actions, targets, and metrics. Disclosures on the EU Taxonomy are usually found in the environmental chapter.
- Annex: index of disclosure requirements with a reference to where each is reported
This is reflected in the following examples of CSRD reporting (based on the 2023 ESRS):
- BASF (chemicals): consolidated sustainability statement in the combined management report 2025
- Henkel (consumer goods): sustainability statement, integrated into the annual report for the first time in 2025
- Aixtron (semiconductor equipment): integrated into the annual report 2025, with references to the data points directly in the text
- Villeroy & Boch (consumer goods): stand-alone sustainability report 2025 outside the management report
Applying the ESRS: working tools and latest developments
For financial year 2026, companies can choose: the previous ESRS, the revised ESRS, or the previous ESRS with selected reliefs from the revised version. The basis for data collection is the EFRAG list of data points. A draft has been available since August 2026, and the final version is expected by the end of 2026. EFRAG provides the ESRS themselves, Q&As, and implementation guidance free of charge in its Knowledge Hub.
Three bodies reliably reflect the latest state of the discussion:
- EFRAG: develops the ESRS and publishes the list of data points and implementation guidance
- DRSC (Accounting Standards Committee of Germany): follows German implementation and comments on every legislative step
- European Commission: legal texts and Q&As on the CSRD
Frequently asked questions about the CSRD reporting requirements
Not as of October 2026. The German CSRD Implementation Act is before the Bundestag. A first draft lapsed at the end of the previous legislative period, and the current draft has been available since September 2025. Until it enters into force, the non-financial statement under the CSR-RUG applies. The EU deadline for transposition is March 19, 2027. The DRSC documents the latest status.
The EU uses the term omnibus for a legislative package that amends several sets of rules in one step. The Omnibus I sustainability package has been in force since March 2026. For the CSRD, it raises the thresholds, which means fewer companies fall under the reporting requirements. It also simplifies the ESRS and keeps assurance at the limited level. Sector-specific standards become voluntary, and data requests to smaller suppliers are capped. The blog article CSRD-Berichtspflicht: Wer betroffen ist und was das bedeutet (in German) explains the new thresholds in detail.
The assessment is mandatory and determines the content of the report. Preparation can still start early: define the scope of consolidation, clarify responsibilities, and build up data on the topics that prove material in most assessments, such as climate change, own workforce, and business conduct.
Yes, with limited assurance for the time being. The auditor confirms that nothing has come to their attention during the review that indicates a material misstatement.
Yes, especially for voluntary and internationally oriented reports. GRI is widely used around the world and easy to work with, and many disclosures can be transferred between GRI and the ESRS. For companies subject to reporting requirements, the ESRS are authoritative.
VSME stands for “Voluntary Sustainability Reporting Standard for non-listed SMEs”, a voluntary EU standard for smaller companies outside the scope of the CSRD. It consists of a basic module and a more comprehensive module. It is useful for companies that are asked for sustainability data by customers, banks, or investors and are looking for a lean, recognized framework. The European Commission adopted it in July 2026 together with the revised ESRS.
Companies subject to reporting requirements also need data from their supply chain for their CSRD report. To prevent suppliers outside the scope from being overwhelmed by ever new questionnaires, there is a cap. From financial year 2027, customers may request at most the disclosures of the VSME standard for their CSRD report. Requests made for other reasons are not covered, for example under supply contracts or the EU Deforestation Regulation.
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