Framework · ESRS

CSRD Compliance Guide: Navigating EU Sustainability Reporting.

Essential insights for US companies navigating EU Sustainability Reporting under the Corporate Sustainability Reporting Directive (CSRD).

AP
Anuraag Paul
Co-Founder & Chief Sustainability Officer, Newtral
Published
February 1, 2024
Last reviewed
February 1, 2024
Read time
3 min · 802 words
Current
A compass resting on a map, symbolizing navigation and direction
Key takeaways
  • 01The CSRD reaches beyond the EU — US companies with listed securities, large EU subsidiaries, or large EU group entities can fall within its scope.
  • 02Double materiality requires reporting both how sustainability issues affect the business and how the business affects sustainability — with mandatory third-party assurance.
  • 03With national transposition due by July 2024 and some reporting starting for FY2024, US companies need to scope, plan, and engage stakeholders now.

The European Union's new Corporate Sustainability Reporting Directive (CSRD) is not just a game-changer for EU companies – it also has major implications for US businesses with operations or subsidiaries in the EU. As the new rules take effect and member states begin to translate them into national law, it's critical that US companies stay on top of the requirements and take proactive steps to comply.

US companies with EU ties can't afford to sit this one out.

But with so many new acronyms and standards to navigate – from the CSRD itself to the 12 new European Sustainability Reporting Standards (ESRS) – it can be challenging to know where to start. That's where this practical guide comes in. As someone who has spent their career [advising companies on sustainability strategy / building ESG reporting tools / whatever your relevant background is], I've seen firsthand the challenges and opportunities that come with this new era of sustainability reporting. My goal is to help US companies make sense of the EU's expanding rulebook and position their businesses for success in the years ahead.

So let's dive in. The first thing US companies need to understand is who is covered by the CSRD. The directive applies to three main categories of companies:

Listed companies

Companies with securities listed on an EU-regulated market, including both EU and non-EU entities with listed debt or equity securities (with limited exceptions).

Large unlisted EU companies

"Large" EU companies that are not listed, defined as those exceeding certain asset, revenue, and workforce size thresholds in two consecutive years. This includes EU subsidiaries of US companies that meet the criteria.

Large unlisted EU group entities

EU companies that are part of a "large group" and not listed, encompassing EU entities (including EU subsidiaries of US companies) that are parents of a group exceeding certain size thresholds in two consecutive years.

In addition, consolidated sustainability reporting will be required for non-EU headquartered companies at a global level if they generate a certain amount of revenue in the EU and have at least one EU subsidiary or branch that meets the criteria. There are some exemptions depending on how the company consolidates its sustainability reporting.

Once you've determined whether your company is covered by the CSRD, the next step is to understand what you'll need to disclose. The CSRD requires comprehensive and granular disclosures covering the entire spectrum of sustainability topics, as detailed in the 12 new ESRS standards. These disclosures span everything from sustainability strategy and targets to products and services, business relationships, and incentive programs. Importantly, the information reported may not be limited to a company's own operations but could extend to direct and indirect business relationships across the value chain – a potentially challenging area given the scope and reliance on third-party information.

Another key concept to understand is "double materiality."

Double materiality

Companies must report not only on how sustainability matters affect their business development and performance, but also on the impact they have on a range of sustainability matters.

The CSRD also introduces a mandatory assurance obligation for all reported sustainability information – a notable difference from the US Securities and Exchange Commission's proposed climate disclosure rule.

So what does all of this mean for your sustainability reporting strategy?

With EU member states required to incorporate the CSRD's provisions into national law by early July 2024, and reporting set to begin as early as fiscal year 2024 for some companies, it's imperative to start preparing now. Key steps include:

STEP 01

Evaluate scope and timing

Evaluate the scope and applicable effective dates of the CSRD for your company, as well as any alternatives for reporting at different levels within the organization.

STEP 02

Understand the disclosure requirements

Understand what compliance with the disclosure requirements will entail, including which sustainability matters are material and consideration of the EU taxonomy.

STEP 03

Build an implementation plan

Create an implementation plan that includes understanding the wide-ranging disclosure requirements and the expected effort to obtain information and develop and implement reporting systems.

STEP 04

Engage key stakeholders

Engage key stakeholders across the organization to ensure a coordinated and comprehensive approach to compliance. This includes the chief financial officer, chief sustainability officer, and legal counsel.

While the CSRD may seem daunting at first, with the right strategy and preparation, it can also be an opportunity for US companies to strengthen their sustainability reporting and position themselves for long-term success in the EU market.

By taking a proactive and integrated approach to compliance, companies can not only meet the new requirements but also gain valuable insights into their sustainability performance and impacts, identify areas for improvement and innovation, and build trust and credibility with key stakeholders.

The EU's sustainability reporting rulebook is complex and ever-evolving, but with the right roadmap and mindset, US companies can navigate the challenges and emerge as leaders in this new era of corporate sustainability. The time to act is now – your company's future in the EU market may depend on it.

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About the author
Anuraag Paul
Co-Founder & Chief Sustainability Officer, Newtral
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