CSRD guide 2025-2026: obligations, deadlines and

Companies already generate much of the environmental, workforce and governance data needed for CSRD through energy use, purchases, suppliers, employees, operations and internal controls. The challenge is structuring that information so it can support reporting and compliance, savings analysis and operational decisions.

The CSRD Directive, or Corporate Sustainability Reporting Directive, has changed the way European companies disclose sustainability information.

It is not just another regulation. It establishes a new sustainability-disclosure framework that affects more than 50,000 companies in the EU and introduces requirements intended to be as rigorous as those for financial information.

If your company meets certain size criteria or is publicly traded, it may already be required, or may soon be required, to disclose information under CSRD and the ESRS standards. If it does not directly affect you yet, key clients or suppliers may still ask for environmental data to support their own obligations.

This article explains which companies are affected, how the application deadlines work, what information needs to be disclosed and how the ESRS standards structure the process.

Sustainability information is now measurable, auditable and increasingly strategic. Building an efficient CSRD process can help companies respond to regulation while improving data quality, operational visibility and competitiveness.

What is the CSRD Directive and why does it matter?

Directive (EU) 2022/2464, known as CSRD, establishes mandatory sustainability-disclosure requirements for thousands of companies in Europe.

Its objective is to bring corporate transparency on environmental, social and governance matters closer to the level of rigor expected for financial information.

The directive also changes how companies manage information internally. CSRD requires organisations to connect source data, materiality assessments, governance, evidence and assurance instead of treating the final document as a standalone exercise.

What CSRD requires companies to do

Companies covered by the directive must:

• Publish an annual sustainability statement integrated into their management report.
• Follow the European Sustainability Reporting Standards (ESRS).
• Submit the statement to external verification by an independent auditor through a limited-assurance process.
• Present the information in digital XHTML format with data tagging to facilitate accessibility and analysis by investors and regulators.

These requirements mean that companies need repeatable data processes, clear ownership and evidence that can be traced from the final disclosure back to the original source.

The principle of double materiality

One of the key concepts in CSRD is double materiality, which requires companies to assess environmental, social and governance matters from two perspectives:

1. Impact materiality: how the company’s activities affect society and the environment.
2. Financial materiality: how environmental, social and governance matters create risks or opportunities for the company itself.

This means that measuring an environmental footprint is not enough. Companies also need to analyse how climate change, social risks and governance matters can affect financial performance, strategy and business continuity.

The double materiality assessment determines which ESRS topics are material and therefore which disclosures, metrics and evidence the company needs to prepare.

Which companies are required to report under CSRD

CSRD expands the number of companies required to provide sustainability information. It no longer affects only large listed corporations, but a much broader group of organisations.

Large companies (the bulk of those obligated)

All companies that meet at least two of these three criteria are obligated:

• At least 250 employees on average.
• At least €40 million in annual net turnover.
• At least €20 million in total balance-sheet assets.

These conditions define large companies in the EU, including both private and listed organisations. It is estimated that around 50,000 companies in the EU fall within this scope.

Listed companies (including SMEs)

Companies listed on EU-regulated markets are subject to CSRD regardless of their size, except for micro-enterprises.

This includes listed SMEs, although certain reliefs and simplified standards are available to them.

Third-country companies with EU presence

The directive also reaches non-European business groups with substantial activities in the EU.

Specifically, a company from a third country may be required to disclose information if it:

• Generates more than €150 million in annual revenue in the EU.
• Has at least one large or listed subsidiary in the EU, or a branch with more than €40 million in business.

These companies must prepare a consolidated sustainability statement covering their EU operations according to CSRD requirements.

4 phases of the CSRD implementation calendar

CSRD implementation is phased, with different dates depending on the type and size of company. The following calendar reflects the 2025 modifications described in the original framework.

Phase 1: Large public interest companies (already in force)

Affected companies: Large listed or financial companies with >500 employees (already subject to the previous NFRD directive)

• First covered fiscal year: 2024
• Publication of first report: 2025

These companies are already reporting under CSRD since fiscal year 2024.

Phase 2: Other large companies (POSTPONED)

Affected companies: Other large EU companies (≥250 employees, ≥€40M turnover, ≥€20M assets)

• Original calendar: Fiscal year 2025 (report in 2026)
• Revised calendar after “stop-the-clock”: Fiscal year 2027 (report in 2028)

The “stop-the-clock” Directive approved in April 2025 postponed the entry into force by two years for these companies, giving them more preparation time.

Phase 3: Listed SMEs (POSTPONED)

Affected companies: Small and medium-sized companies listed on regulated markets (excluding micro-enterprises)

• Original calendar: Fiscal year 2026 (report in 2027)
• Revised calendar: Fiscal year 2028 (report in 2029)

Listed SMEs also benefited from the two-year postponement and will be able to use a simplified standard (VSME).

Important note: There are proposals under negotiation (Omnibus I) to exclude companies between 250 and 1,000 employees from the mandatory scope, but as of late 2025 these modifications are not yet in force.

Phase 4: Third-country companies

Affected companies: Non-EU groups with revenues >€150M in the EU and significant subsidiaries/branches

• First covered fiscal year: 2028
• Publication of first report: 2029

This calendar remains unchanged from the original plan.

ESRS standards: the technical framework for ESG reporting

To comply with CSRD, companies must report following the European Sustainability Reporting Standards (ESRS) developed by EFRAG (European Financial Reporting Advisory Group).

ESRS are a set of technical standards that specify in detail what ESG information must be disclosed and how. Their objective is to standardize reporting in the EU, providing comparability and rigor.

ESRS structure: 12 standards in total

The first set of ESRS consists of 12 standards, divided into two categories:

Cross-cutting standards (2 general standards)

ESRS 1 – General Requirements: Defines how to perform the double materiality assessment and other reporting principles that all companies must follow.

ESRS 2 – General Disclosures: Specifies mandatory disclosures on sustainability governance, business model, strategy, materiality processes, policies, and management systems.

These two standards establish the common basis that all companies must comply with, regardless of their sector or specific situation.

Topical standards (10 specific standards)

The 10 topical standards cover environmental, social, and governance areas. Companies must apply them only if they consider the topic material after their double materiality analysis.

Environmental Standards (ESRS E1 to E5):

• ESRS E1 – Climate Change: Mitigation and adaptation, GHG emissions (scopes 1, 2, 3), energy consumption, decarbonization strategies, and climate transition plans
• ESRS E2 – Pollution: Air, water, and soil pollution; pollutant emissions, hazardous substance management
• ESRS E3 – Water and marine resources: Water extraction and consumption, discharges, impact on marine resources
• ESRS E4 – Biodiversity and ecosystems: Impact on biodiversity, habitat loss, ecosystem services
• ESRS E5 – Circular economy: Raw material use, waste generated, recycling and reuse strategies

Social Standards (ESRS S1 to S4):

• ESRS S1 – Own workforce: Working conditions, wages, health and safety, training, equality, diversity, gender pay gap
• ESRS S2 – Workers in the value chain: Working conditions and human rights of suppliers and contractors
• ESRS S3 – Affected communities: Impact on local communities, respect for economic, social, and cultural rights
• ESRS S4 – Consumers and end-users: Product safety, data protection, responsible marketing, accessibility

Governance Standards (ESRS G1):

• ESRS G1 – Business conduct: Corporate culture, ethics, prevention of corruption and bribery, whistleblower protection, business partner relations, lobbying, animal welfare

Flexibility based on materiality

Companies can omit information from a standard if they conclude the topic is not material, although they must briefly explain that conclusion.

The most significant exception is ESRS E1, Climate Change. If climate change is considered non-material, the company must provide an explicit and detailed justification.

This flexibility does not mean that companies can ignore topics without evidence. The materiality assessment must be documented, repeatable and supported by the perspectives of affected stakeholders and business functions.

Relief measures for the transition

To facilitate adoption, the regulation provides gradual reliefs during the first years:

• Companies with fewer than 750 employees can omit Scope 3 emissions and certain workforce data during their first year.
• During the first two years, companies can omit detailed information on biodiversity under E4 and workers in the value chain under S2.
• During the first year, companies can provide qualitative descriptions of anticipated financial effects from climate change.

These measures reduce the initial burden, but companies should still structure the underlying data early. Building a reliable process takes time, especially when information comes from suppliers, subsidiaries and operational systems.

What practical information needs to be reported

Under CSRD, companies must collect a wide variety of quantitative and qualitative data on their ESG impacts, risks, and performance. Let’s see what each dimension includes:

Environmental Dimension: your footprint and approach to environmental sustainability and environmental management

Emissions and climate:

• GHG emissions detailed by scopes (1, 2, and 3)
• Energy consumption and energy efficiency measures
• Climate neutrality transition strategy
• Analysis of climate risks and opportunities (aligned with TCFD)

Pollution and resources:

• Pollutant emissions to air and water discharges
• Hazardous waste management
• Water resource use (extraction, recycling, impact on basins)
• Percentage of reused or recycled materials

Biodiversity:

• Operations in or near protected areas
• Impact on ecosystems and species (deforestation, land use)
• Restoration or compensation initiatives

Examples of specific indicators: Tons of CO₂ emitted, carbon footprint per revenue unit, energy intensity, volume of recovered waste, water consumption by source.

Social Dimension: impact on people

Internal labor practices:

• Number of employees (broken down by contract type, gender, location)
• Equality and diversity policies (women in management, gender pay gap)
• Training and professional development (training hours)
• Occupational health and safety (accident rates)
• Working conditions (schedules, work-life balance, living wage)

Supply chain:

• Supplier monitoring on labor rights
• Audits of critical suppliers
• Prevention of child labor and forced labor
• Safe conditions and living wage in the chain

Local communities:

• Impacts of operations on communities
• Social investments and public consultations
• Management of displacements or impacts

Customers and consumers:

• Product and service safety
• Personal data protection and cybersecurity
• Responsible advertising
• Access for vulnerable groups

Examples of indicators: Employee injury rate, proportion of critical suppliers evaluated on social matters, number of customer complaints related to privacy.

Governance Dimension: ethics and transparency

Sustainability governance:

• ESG governance structure and roles (committees, responsible persons)
• Frequency of Board discussions
• ESG competencies of management
• Linking management remuneration to ESG objectives

Corporate ethics:

• Anti-corruption and anti-bribery policies
• Code of ethics and compliance training
• Internal controls to prevent fraud
• Detected corruption incidents and investigations

Integrity and transparency:

• Confidential whistleblowing channels
• Whistleblower protection
• Tax policy and country-by-country reporting
• Lobbying activity and political contributions

Third-party management:

• Supplier ethics monitoring
• Anti-corruption practices in contracts with third parties
• Average payment times to suppliers

How to prepare for CSRD compliance

Preparing for CSRD is not a one-time procedure. It is a structural change in how companies manage and communicate environmental, social and governance information.

1. Conduct a double materiality analysis

The first step is to identify which environmental, social and governance topics are material from both impact and financial perspectives.

This analysis determines which ESRS standards the company must apply in depth and helps prioritise data-collection efforts.

A documented materiality process also gives teams a defensible explanation for why certain topics, metrics or locations are included or excluded.

2. Map and centralize ESG data sources

Identify where the information is stored, including ERP systems, CRM systems, spreadsheets and supplier records. Then establish processes to consolidate the data in an automated and traceable way.

This is where a platform such as Dcycle can make a difference. Instead of working with multiple dispersed tools, companies can structure their environmental, operational, workforce and governance information in one system that:

• Integrates directly with data sources.
• Automates collection and normalisation.
• Keeps data updated consistently.
• Maintains traceability for audits and assurance.

3. Implement automated reporting systems

Manually compiling sustainability disclosures creates unnecessary delays and increases the risk of inconsistent information. Companies need a solution that can:

• Generate outputs according to the applicable ESRS.
• Adapt the format to each framework, including CSRD, SBTi, EU Taxonomy and ISO standards.
• Maintain coherence and consistency across disclosures.
• Prepare the required XHTML format with digital tagging.

Reporting is one output of the data. The same information should also support savings analysis, supplier management and operational decisions.

4. Prepare for external verification

The CSRD statement must be reviewed by an independent third party. This means the underlying information must be:

• Documented: Each metric has clear evidence and calculation logic.
• Traceable: The company can follow the audit trail from the output back to the source.
• Verifiable: Internal quality-control processes identify and correct errors before assurance.

5. Train teams and assign responsibilities

Environmental data management is not only the responsibility of the sustainability department. It involves:

• Legal and compliance
• Finance and accounting
• Human resources
• Operations and supply chain
• General management

Every team should understand its responsibilities for generating, collecting, validating and approving information.

Clear ownership prevents data gaps and makes it easier to maintain the process throughout the year instead of rebuilding it just before the deadline.

Official tools and resources for implementation

The EU and technical bodies have developed multiple resources to facilitate compliance:

Official documentation and technical guides

• CSRD Directive text and the ESRS Delegated Act (available on Eur-Lex)
• EFRAG implementation guides (Implementation Guidance) on:
  • IG 1: How to perform the materiality assessment step by step
  • IG 2: How to collect value chain data
  • IG 3: Complete inventory of datapoints required by ESRS
• Q&A platform from EFRAG/Commission for frequent questions

Simplified standards for SMEs

The European Commission issued in 2025 a Recommendation for a voluntary SME standard (VSME): a simpler and more proportionate framework that SMEs can use voluntarily.

Listed SMEs can use it as preparatory guidance before their mandatory entry into force.

Technological tools

• XBRL digital taxonomy for ESRS: allows electronic tagging of each data point
• ESEF platform (European Single Electronic Format): now incorporates sustainability tags
• Corporate reporting software with integrated ESRS templates

National regulator communications

Bodies such as CNMV and ICAC in Spain have published guidance communications, FAQs, and guidelines for auditors on how to address CSRD.

Additional resources to go deeper on CSRD, ESRS and sustainability reporting

If this guide works as your high level framework, the next step is execution: confirming whether CSRD applies, deciding what to report, aligning with ESRS, staying on top of 2025 changes, and preparing digital reporting that is consistent and auditable.

Below you have a curated set of complementary resources that expand each critical area, with a practical angle focused on common pitfalls, key decisions, and how to structure the work so you do not waste months on low impact tasks.

The starting point is always scope.

Many teams move too fast into templates and data requests, only to discover later that the company falls under different timing, thresholds, or consolidated reporting rules than they assumed.

Before building anything, validate the perimeter with CSRD obligated companies, which helps you clarify who is in scope, what triggers the obligation, and how to interpret the criteria in a realistic way. Once you know you are in scope, it is also useful to strengthen your understanding of what “CSRD reporting” means beyond the headline.

The obligations are not just about publishing a document, they reshape how you manage governance, traceability, and evidence across the organisation.

That leads to the next common mistake: thinking the deliverable is purely editorial.

Under CSRD, a “report” is inseparable from the system that produces it. If you want a clear operational view of what is expected and what changes compared to older sustainability disclosures, read mandatory sustainability report.

It helps you see the reporting effort as a cross functional program, not as a year end communication exercise.

This framing matters because it affects timelines, internal ownership, and the way you design data collection from the start.

Once the perimeter is clear, the core methodological engine is double materiality. Doing it as a box ticking exercise usually creates a domino effect: irrelevant disclosures, unmanageable data gaps, and a report that is hard to defend when challenged.

To structure the analysis properly and connect impacts, risks and opportunities to what must end up in the report, use CSRD double materiality.

In practice, a good double materiality process becomes a prioritisation tool. It reduces noise, prevents over reporting, and gives you a logical foundation for deciding which ESRS topics, metrics and narratives you actually need.

On top of that, 2025 introduces moving pieces that you should not ignore if you are designing your roadmap now.

The danger is either under reacting and missing an update that changes what you should prepare, or over reacting and rebuilding everything unnecessarily.

To understand what has changed and how it may affect companies reporting under CSRD, review ESRS changes 2025 and what the quick fix means.

Use it to separate changes that affect content from those that affect structure or sequencing, and to adjust your plan without improvising.

Another critical block is the relationship between CSRD and the EU Taxonomy.

Many organisations treat them as parallel streams, which often results in duplicated work, inconsistent definitions, and numbers that do not reconcile across frameworks.

If you want a more integrated approach, this resource helps connect the dots: Dcycle and the EU Taxonomy: how to accelerate regulatory compliance.

The practical takeaway is that you should design shared data foundations and traceability early, because both CSRD and Taxonomy depend on consistent activity classification, evidence, and defensible calculations.

As you mature the project, digital reporting becomes unavoidable. CSRD pushes sustainability reporting toward formats that are more structured, more comparable, and easier to review at scale.

That is why it is worth understanding the implications of report XBRL. You do not need to be technical to benefit from this.

The key is to realise that digital tagging and structured reporting can change how you build your internal process, how you manage source data, and how you keep consistency across reporting cycles.

If you account for this early, you avoid ending up with a narrative heavy report that is painful to convert into robust, repeatable outputs.

In Spain, it is also useful to monitor official signals because they influence interpretation, expectations, and how companies approach evidence and governance in the early years of CSRD. For context on the local regulatory conversation, see official CSRD communication from ICAC and CNMV.

This can help you avoid relying only on generic EU level summaries without considering how the Spanish environment frames the topic, especially when it comes to documentation and defensibility.

If your focus is to accelerate implementation, tooling can play a role, but software selection is often noisy.

Not every ESG tool is suitable for CSRD grade reporting, because CSRD requires stronger structure, traceability, and governance than many “nice dashboard” platforms provide.

To compare options from a capability perspective, use best CSRD software. Treat it as a checklist of what you should expect from a solution: data capture, workflows, controls, auditability, ESRS alignment, and outputs that support reporting rather than just visualisation.

The goal is not to buy tools for the sake of it, but to reduce coordination cost and improve the repeatability of your process.

A different confusion point is mixing CSRD with related frameworks.

Teams often blend “reporting” and “due diligence” discussions, which can derail ownership and sequencing. To keep the boundaries clear, read CSDDD vs CSRD.

Understanding what each framework is for, and how they can complement each other, helps you avoid building a system that conflicts with itself or assigns responsibilities in a way that does not scale.

Finally, when you are in execution mode, the highest value content is the one that helps you prioritise and reduce uncertainty. If you want a practical way to translate requirements into an implementation approach, use effective CSRD regulations.

If you are getting blocked by recurring doubts, misinterpretations, or edge cases, CSRD clarifications is a useful companion to resolve ambiguity without inventing your own rules.

And if you need a clean order of operations to structure the programme, especially when resources are limited, rely on how to prioritise the CSRD directive, which helps turn “we must comply” into a sequenced plan with owners, dependencies, and concrete deliverables.

Used together, these resources move you from “understanding CSRD” to “executing CSRD”.

They help you validate scope, run double materiality properly, adapt to ESRS changes, align CSRD with the EU Taxonomy, prepare for structured digital reporting in XBRL, interpret local regulatory guidance, choose tooling with criteria, distinguish CSRD from CSDDD, and prioritise the work so progress is real, measurable, and repeatable.

How Dcycle supports CSRD data management

When companies implement CSRD, the difference between preparing on time and falling behind is not only understanding the regulation. It is having the right infrastructure to manage the data.

Dcycle provides a data platform for automated data collection that structures environmental, operational, workforce and governance information in one system.

One platform, all standards

One platform for multiple standards

Dcycle is not a consultancy used only occasionally. It is a SaaS data platform that:

• Centralises environmental, operational, workforce and governance information in one system.
• Automates collection from ERP systems, CRM platforms and spreadsheets.
• Structures information for CSRD, ESRS, SBTi, the EU Taxonomy and ISO standards.
• Generates audit-ready outputs without relying on manual consolidation.

Ready for CSRD from day one

While some solutions require complex implementations or custom development, Dcycle is designed to help companies establish a repeatable data process quickly.

With Dcycle:

• Teams can become operational quickly.
• Companies do not need constant external consulting.
• All departments work from the same reliable database.
• Data remains updated and traceable.

Beyond compliance: strategic sustainability

CSRD should not be treated as a formality. The same structured data can support:

• Anticipating future regulations.
• Improving operational performance based on real data.
• Strengthening relationships with investors, clients and administrations.
• Making strategic decisions with reliable information.

The goal is not only compliance. It is to build a data foundation that helps teams identify environmental improvements, respond to requests and make decisions with less manual work.

With Dcycle, CSRD data management becomes a repeatable business process rather than a last-minute reporting exercise.

Frequently asked questions (FAQs)