CSRD Reporting: Who Must Report, What to Include and How to Start
CSRD reporting is the process by which in-scope companies publish a sustainability statement inside their annual management report, following the European Sustainability Reporting Standards (ESRS). The rules were cut back sharply in 2026. Far fewer companies now report directly, but many smaller firms, UK businesses included, still get asked for the same data by customers and lenders. This guide explains who is caught, what the report contains, and what to do next.
Key takeaways
The CSRD is EU law. It does not apply as domestic law in the UK, but UK groups can be caught through EU subsidiaries, branches or EU turnover.
After the Omnibus I changes, the CSRD applies to EU companies with more than 1,000 employees and €450 million net turnover.
Double materiality is the core of the report: you disclose both how sustainability issues affect your business and how your business affects people and the environment.
Smaller firms outside scope are still pulled in by customer questionnaires. Building a tidy data set now is cheaper than answering ad hoc requests later.
The Commission has adopted revised, simpler standards, so any template or example written before July 2026 needs checking.
What CSRD reporting actually is
The Corporate Sustainability Reporting Directive, formally Directive (EU) 2022/2464, amended the EU Accounting Directive. It replaced the older, looser non-financial reporting rules with a requirement that covered companies publish sustainability information in their management report. The information must be structured, comparable and, over time, independently assured.
The European Commission describes the rules as requiring large and listed companies to publish regular reports on the social and environmental risks they face and on their own impact on people and the environment.
Three features separate CSRD reporting from a voluntary sustainability report:
Mandatory content. You follow the ESRS rather than choosing your own topics freely.
Double materiality. Topics are selected by an assessment of both impact and financial relevance.
Part of the management report. The statement sits alongside the financial statements, is digitally tagged, and is subject to assurance.
Who has to report after Omnibus I
The original CSRD would have covered tens of thousands of companies. The Omnibus I simplification package changed that. According to law firm Crowell’s summary, Omnibus I was adopted and entered into force on 19 March 2026, and it raised the thresholds so that only the largest companies remain in scope.
Type of company | Direct CSRD scope (post-Omnibus I) |
EU company | More than 1,000 employees on average and more than €450 million net turnover |
Non-EU group | More than €450 million net turnover generated in the EU, plus an EU subsidiary or branch above a further turnover threshold (€200 million for the subsidiary or branch) |
Company with 1,000 employees or fewer | Outside direct scope, but protected by a value-chain cap if asked for data |
The thresholds above come from the Crowell analysis. Member states must also transpose the changes into national law, so check the position in each country where you operate. Always confirm against the final legal text or with your auditor before deciding that you are in or out.
The value-chain cap
One of the more practical changes protects smaller suppliers. Companies with 1,000 employees or fewer can refuse to provide information beyond voluntary standards, and contrary contract clauses are ineffective. In practice, a large customer should not demand the full ESRS data set from a 200-person supplier.
Does the CSRD apply in the UK?
Not directly. The CSRD is not part of UK domestic law. The UK has its own, separate approach, the UK Sustainability Reporting Standards (UK SRS), based on the ISSB frameworks. According to Travers Smith’s analysis, these standards were voluntary as of the first quarter of 2026 and focus on financial materiality only, so they do not require a double materiality assessment.
That does not mean UK businesses can ignore the CSRD. The same analysis points to three routes by which UK companies are affected:
EU subsidiaries. A UK parent with a large EU subsidiary may see that subsidiary report, or may be pulled into group-level reporting.
Group reporting under Article 40a. Non-EU groups with enough EU turnover and a qualifying EU presence can be required to report.
Supply chains. UK suppliers to in-scope EU firms receive data requests.
If you are a UK finance director, the first question is therefore simple: do we have a subsidiary or branch in the EU, and what are its turnover and headcount? If not, your exposure is probably through customers, which is a commercial matter rather than a legal one.
Why smaller businesses still feel the pressure
Even where a company is technically outside scope, disclosure is becoming a condition of doing business. EY notes in a technical line on multinationals that large financial institutions and EU multinational customers use standardised procurement questionnaires, aligned with the CSRD’s voluntary framework, to collect data from their supply chains.
The practical effect is familiar to many UK suppliers: a bid or renewal arrives with a long sustainability questionnaire. A business that has already measured its emissions, energy use, workforce data and governance policies can answer in a day. One that has not may spend weeks.
Supply chain rules are also tightening in other areas. Our coverage of UK deforestation checks for business supply chains shows how the same pattern repeats: a rule aimed at large firms creates data demands further down the chain.
What goes into a CSRD report
The report is called a sustainability statement. Its content follows the ESRS, which cover environmental, social and governance issues, including climate change. On 3 July 2026 the Commission adopted revised ESRS and a voluntary standard for smaller companies, with the stated aim of reducing administrative burden while keeping disclosures high quality.
A typical structure
Use this skeleton as a working outline for your own statement. It reflects the general layout of the ESRS, but the revised standards changed detailed requirements, so check each datapoint against the current text.
General information. Basis of preparation, business model, strategy, governance of sustainability, and the outcome of your materiality assessment.
Environmental topics. Typically climate change, pollution, water, biodiversity and resource use and circular economy, but only those you found material.
Social topics. Your own workforce, workers in the value chain, affected communities, consumers and end users, again only where material.
Governance. Business conduct, including anti-corruption and supplier relationships.
Policies, actions, targets and metrics. For each material topic: what you do, what you aim for and how you measure it.
Assurance and tagging. Limited assurance from an auditor or accredited provider, and digital tagging of the report.
What a CSRD report template should include
Searchers often ask for a template. A useful one is less a Word document than a data register. For each material topic, record:
the impact, risk or opportunity and whether it is actual or potential;
the policy that addresses it, and who owns it;
the target, the baseline year and the latest result;
the data source, the calculation method and the date last checked;
the evidence an assurance provider would ask to see.
If you can fill that table for every topic, writing the narrative is the easy part. If you cannot, the gap tells you where to start.
Examples of CSRD reporting
Real examples are best taken from companies that have already published. Large EU listed groups reporting for the 2024 and 2025 financial years have put their sustainability statements inside their annual reports, and you can read them on their investor pages. A few cautions when you do:
Compare the structure rather than copying the wording. Each statement reflects that company’s own materiality outcome.
Check the date. Reports prepared before the 2026 revisions may include datapoints that are now simplified or removed.
Read the materiality section first. It shows why some topics were included and others left out.
For a non-CSRD example of a published sustainability report, see our write-up of ERM’s 2024 sustainability report. It is voluntary reporting rather than a CSRD statement, but it shows how a large organisation presents its progress.
Double materiality without the paralysis
Double materiality is where most teams stall. You assess each sustainability matter from two angles: how it affects your financial performance, and how your activities affect people and the environment. A topic that is material from either angle goes into the report.
We explain the method in detail in Understanding Double Materiality in Corporate Sustainability Reporting and compare practical routes in Navigating Double Materiality. For the visual output, our guide to drawing a materiality matrix is a good start.
Two changes in the 2026 simplification help here. The Commission’s delegated act allows companies, when they cannot engage directly with every value chain actor, to use reasonable and supportable information such as average sector or regional data to identify material impacts, risks and opportunities. That removes the need to survey every tier of your supplier network.
The simplification package also includes reliefs that companies can apply early for financial years starting in 2026, including a top-down approach to double materiality and limits on value chain data requirements. If you are preparing your first statement, these reliefs can cut a lot of work, provided you document how you applied them.
How to start: a practical sequence
Confirm your position. Work out whether you are in scope directly, through a group, or only through customers. Ask your auditor or legal adviser to confirm any borderline case.
Map your data owners. Energy and emissions usually sit with facilities or finance, workforce data with HR, supplier data with procurement. Name one person for each.
Run a proportionate materiality assessment. Start with desk research and sector data, then interview a small number of stakeholders. Do not try to survey everyone.
Find the gaps. Compare the data you hold with the datapoints your material topics need. List what is missing and who can supply it.
Build the register. Use the table described earlier. Keep the source and method for each figure.
Draft the statement and test it. Ask someone outside the project to read it and find the claims they cannot verify.
Plan assurance. Agree early with your assurance provider what evidence they need.
A note on frameworks: many companies already report using GRI, and that work is not wasted. The structure of impact reporting under GRI maps well onto the impact side of double materiality. Our GRI Reporting course covers the basics for teams starting from scratch.
Common mistakes to avoid
Treating it as a one-off project. The data must be collected every year, so build processes, not spreadsheets that live in one person’s inbox.
Including every topic. The point of materiality is to leave things out, with reasons.
Chasing perfect supplier data. Use estimates and sector averages where the rules allow, and say that you did.
Ignoring financial-sector effects. Banks face their own simplifications and new disclosure expectations. Our piece on the EBA’s changes to ESG reporting for banks shows how lenders’ needs flow back to their clients.
Copying an out-of-date template. The standards were revised in July 2026, so a template from 2024 may ask for more than you now need.
How Exereco can help
Exereco brings sustainability news, ESG advisory, training, reporting software and networking together in one place, with a focus on European and African organisations. If your team is new to sustainability reporting, our training and advisory work can help you move from a data register to a draft statement, and our news coverage tracks rule changes as they happen. Start at exereco.com to see the options that fit your size and sector.
FAQ
What is a CSRD report?
It is the sustainability statement that in-scope companies include in their annual management report. It covers environmental, social and governance matters, follows the ESRS, and is selected using a double materiality assessment. It is also subject to independent assurance.
Does the CSRD apply in the UK?
Not as UK law. The UK has its own voluntary UK SRS, based on ISSB standards. UK groups can still be affected through EU subsidiaries, branches or turnover in the EU, and UK suppliers may receive data requests from in-scope customers.
What are the criteria for a CSRD report?
For EU companies, the post-Omnibus I test is more than 1,000 employees and more than €450 million net turnover. Non-EU groups face separate EU turnover tests. Confirm against the final text and national transposition for your country.
Do small businesses need to do CSRD reporting?
Not directly. Companies with 1,000 employees or fewer are protected by a value-chain cap on data requests. Even so, customers and lenders may ask for similar information, and a voluntary standard for smaller companies now exists to give those requests a common shape.
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