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Scope of application of the CSRD
Summary
The CSRD’s entry into force is phased in, depending on the type of entities concerned:
1 Large undertakings, in accordance with the definition of the Directive 2013/34/EU (the “Accounting Directive”), exceed the limits of at least two of the three following criteria on the balance sheet date in two consecutive years (total balance sheet and net turnover thresholds as revised by the bill of law transposing the CSRD):
(a) Balance sheet total: EUR 25,000,000.
(b) Net turnover: EUR 50,000,000.
(c) Average number of employees during the financial year: 250.
Exemptions, derogations, and transitional provisions
Subsidiary undertakings are exempted from sustainability reporting if a consolidated sustainability statement is prepared by their parent company, provided that they mention this exemption and refer to the consolidated sustainability reporting of their parent. This exemption does not apply to large undertakings whose transferable securities are listed on a regulated market of a Member State.
For the first two years of application (2026 and 2027 financial years), SMEs whose transferable securities are listed on EU regulated markets may decide to opt-out from CSRD reporting requirements. In such cases, they shall briefly state in their management report why the sustainability reporting has not been provided.
More generally, transitional provisions have been set in relation to disclosure requirements as regards:
- Entity-specific disclosures for the first 3 annual sustainability reports.
- Value chain: for the first 3 years of their sustainability reporting under the ESRS, undertakings may limit upstream and downstream value chain information on policies, actions, and targets to information available in-house, and may omit upstream and downstream value chain information when disclosing certain metrics.
- Undertakings with less than 750 employees may omit:
- Scope 3 GHG emissions data and the disclosure requirements specified in the standard on “own workforce” in the first year that they apply the standards.
- The disclosure requirements specified in the standards on biodiversity and on value-chain workers, affected communities, and consumers and end-users in the first two years that they apply the standards.
- Presenting comparative information: omission of comparative permitted for the first year of reporting.
Please refer to ESRS 1, Chapter 10 and Appendix C, for more detailed information about transitional provisions and phased-in disclosure requirements for each ESRS standard.