CSRD — Corporate Sustainability Reporting Directive

Overview

The Corporate Sustainability Reporting Directive (CSRD) — Directive (EU) 2022/2464 — requires large companies to report on sustainability matters using the European Sustainability Reporting Standards (ESRS). The scope was dramatically narrowed by the Omnibus simplification package in February 2026.

Legal basis

• Proposed: 21 April 2021
• Adopted: 16 December 2022
• Entered into force: 5 January 2023
• Significantly amended: Omnibus package (published OJ 26 February 2026)

Post-Omnibus scope

The Omnibus package removed approximately 80% of originally in-scope companies:

New thresholds:

• EU companies: >1,000 employees AND >450 million net turnover
• Non-EU companies: >450M net turnover generated in EU
• Listed SMEs: removed from mandatory scope entirely

Reporting standards (ESRS)

Companies report against European Sustainability Reporting Standards:

• ESRS 1: General requirements
• ESRS 2: General disclosures
• ESRS E1-E5: Environmental (climate, pollution, water, biodiversity, resource use/circular economy)
• ESRS S1-S4: Social (workforce, value chain workers, communities, consumers)
• ESRS G1: Governance

ESRS E5 (Resource use and circular economy) has direct relevance to DPP product data.

Timeline

| Date | Event | |------|-------| | FY 2024 | Wave 1 reports (formerly NFRD companies >500 employees) | | April 2025 | "Stop-the-clock" directive — 2-year extension for Waves 2 & 3 | | 26 February 2026 | Omnibus published — scope substantially narrowed | | FY 2027 | Remaining in-scope companies (>1,000 employees, >450M) report |

Who is affected

• Wave 1 (already reporting for FY 2024): Companies formerly subject to the Non-Financial Reporting Directive (NFRD) — approximately 11,700 large listed companies, banks, and insurers with more than 500 employees
• Wave 2 (from FY 2027): EU companies with more than 1,000 employees AND more than €450 million net turnover; Non-EU companies generating more than €450 million net turnover in the EU
• Listed SMEs: Removed from mandatory scope entirely by the Omnibus package (February 2026)
• Value chain SMEs: May receive questionnaires from in-scope companies; a voluntary SME standard is being developed

Penalties and enforcement

The Omnibus Directive (EU) 2026/470 retained but adjusted the CSRD penalty framework:

• Maximum administrative fine: up to 3% of net worldwide turnover for non-compliance
• EU-wide civil liability regime was deleted by the Omnibus — national civil liability rules now apply
• Audit assurance requirement reduced to limited assurance only (reasonable assurance requirement removed)
• The Commission will issue guidelines to national supervisory authorities on penalty calibration

Non-compliance consequences include: fines at national authority discretion, reputational harm from mandatory public disclosure, and exclusion from certain procurement procedures.

Double materiality

CSRD requires companies to assess sustainability matters using double materiality — evaluating both:

• Impact materiality: How the company's activities affect people and the environment
• Financial materiality: How sustainability risks and opportunities affect the company's financial position

This dual assessment determines which ESRS standards and data points must be disclosed. ESRS E5 (Resource use and circular economy), including DPP-adjacent metrics on recyclability, recycled content, and material flows, is subject to double materiality assessment.

Relevance to DPP

CSRD and DPP are designed as complementary data systems:

• ESRS E5 demands disclosure on material resource flows, recyclability, recycled content
• Companies must disclose circular economy policies at product level
• CSRD disclosures can leverage DPP data for automated reporting
• Product-level DPP data aggregates into corporate-level CSRD reporting

Key articles

• Article 19a (as amended): Content of sustainability reporting
• Article 29b: European Sustainability Reporting Standards (ESRS)
• ESRS E5: Resource use and circular economy — most relevant to DPP product data

Source

• Directive (EU) 2022/2464 — EUR-Lex
• Omnibus Directive (EU) 2026/470 — EUR-Lex