The government draft of the Corporate Sustainability Reporting Directive (RegE CSRD) is now available. Implementation this year is therefore becoming increasingly likely. But what does this mean?
- Public-interest companies with more than 1,000 employees, a balance sheet total of over EUR 25 million, or a turnover of over EUR 50 million must report in accordance with the Corporate Sustainability Reporting Directive (CSRD) in 2026 for the 2025 financial year. While this should not come as a surprise to these companies, the interesting question is what form the ESRS will take by then.
- Large companies must report for the 2027 financial year by 2028 at the earliest. Therefore, it is advisable to start preparing well in advance of 2026. It is hoped that the Second Omnibus Directive will have clarified which companies are included in the “large companies” category by then. It is very likely that companies or groups of companies with fewer than 1,000 employees will be excluded.
- Voluntary reporting is becoming increasingly important for companies not subject to reporting requirements. This is because companies subject to reporting requirements are demanding sustainability information within their value chains. In some cases, this information is required independently of reporting requirements within existing or new contractual relationships. To accommodate this trickle-down effect, the Commission (C(2025) 4984 final) advises unlisted SMEs and micro-enterprises to use the voluntary sustainability reporting standard for small and medium-sized enterprises (VSME). Based on this standard, a voluntary standard will also be created for all companies that are not subject to reporting requirements but wish or need to report voluntarily. This will most likely affect numerous companies with fewer than 1,000 employees after the Second Omnibus Directive is implemented.
