CSRD: guide to sustainability reporting

Short answer: The CSRD (Directive (EU) 2022/2464) requires large and listed EU companies to publish detailed sustainability disclosures under the European Sustainability Reporting Standards (ESRS). A large undertaking meets at least two of three criteria: balance sheet total above EUR 25 million, net turnover above EUR 50 million, or more than 250 employees — thresholds raised by 25% via Delegated Directive (EU) 2023/2775 for financial years starting on or after 1 January 2024. Implementation is phased; the Stop-the-Clock Directive (EU) 2025/794 delayed waves 2 and 3 by two years.

Scope and thresholds

The CSRD entered into force on 5 January 2023, amending Directive 2013/34/EU (the Accounting Directive). A company falls in scope when it meets at least two of the three size criteria:

• Balance sheet total: more than EUR 25 million
• Net turnover: more than EUR 50 million
• Employees: more than 250

These thresholds apply to financial years commencing on or after 1 January 2024. They were set by Delegated Directive (EU) 2023/2775, which raised the previous values (EUR 20 million balance sheet, EUR 40 million turnover) by 25% to account for inflation.

For non-EU undertakings operating in the EU through subsidiaries or branches, a separate threshold applies: consolidated net turnover above EUR 150 million within the EU.

Reporting obligations and ESRS

Under Article 19a (individual companies) and Article 29a (consolidated level), in-scope undertakings must report on environmental, social, human rights and governance matters — following the double materiality principle. Reporting must comply with the European Sustainability Reporting Standards (ESRS), adopted on 31 July 2023 and published in the Official Journal on 22 December 2023. An external auditor must provide limited assurance on the sustainability report.

Phased implementation and current delays

Implementation follows four waves:

Wave	Target group	Reporting start (after Stop-the-Clock)
1	Large public-interest entities with more than 500 employees (previously subject to NFRD)	2025 (for FY 2024) — no delay
2	Other large undertakings	2028 (for FY 2027)
3	Listed SMEs, small credit institutions, captive insurers	2029 (for FY 2028)
4	Non-EU undertakings	2029 (for FY 2028)

Stop-the-Clock Directive (EU) 2025/794 (Official Journal, 14 April 2025) delayed waves 2 and 3 by two years. Wave 1 remains unchanged.

Omnibus simplification

On 26 February 2025, the Commission published the Omnibus I proposal (COM(2025) 80), seeking to limit CSRD scope to companies with more than 1,000 employees. The Council reached a political agreement on 9 December 2025. The final text had not yet been published in the Official Journal at the date of this dossier; existing obligations remain in force until the transposition deadline lapses.

Supervision in the Netherlands

The Dutch Authority for the Financial Markets (AFM) supervises compliance by listed companies. The Netherlands' implementing legislation had not been finalised by mid-2026, partly due to political circumstances. Wave-1 companies reported nonetheless, relying on the direct effect of the directive.