Who Does It Apply To?
2024 (First Wave)
Entities previously under NFRD, typically:
- Listed companies with at least 500 employees.
2025 (Second Wave)
Entities meeting two of the following criteria:
- €50 million revenue;
- €25 million balance sheet;
- 250 employees.
2026
What Does It Mean?
The company must:
- Conduct a double materiality assessment;
- Digitally tag and transform the report into a machine-readable format; and
- Based on the results, report all relevant ESRS requirements.
Double Materiality Assessment
- This should be conducted before the first reporting year to define what needs to be reported and what doesn’t.
Preparation Timeline
- Preparation should begin before the first reporting year.
- Companies must report the impacts, risks, and opportunities in force during the reporting year.
- For example, second wave companies will report the policies, actions, and targets in force during 2025. This means these need to be developed during 2024.
ESRS Requirements
- Over 3,000 unique disclosure requirements.
- These can be limited during the double materiality assessment—only material topics and disclosures need to be reported.
- Requirements include:
- Narrative disclosures (majority);
- Specific numerical disclosures (significant amount).
CSRD Report
- Typically 50–300 pages long.
- Must fulfill all ESRS requirements.
Key Points for Entities
For each material sustainability topic, the entity must:
- Disclose relevant policies, actions, and targets; or
- State that these don’t exist.
What to Do Next
- Clarify if and when CSRD requirements apply to your organization.
- Before the first reporting year:
- Conduct a double materiality assessment.
- Map if you have policies, actions, and targets related to material topics. If not, prepare them.
- During the first reporting year:
- Write all narrative disclosures.
- Prepare systems to gather all required numerical data.
- Acquire software that can automatically tag the report.
How Can Sustashift Help?
The Sustashift C-Tag platform:
- Helps fulfill all mandatory disclosure requirements.
- Automatically tags the report.
