Reporting ESG

ESG reporting refers to the structured disclosure of a company's environmental, social, and governance performance, risks, and impacts. Under the Corporate Sustainability Reporting Directive (CSRD), ESG reporting has evolved from a voluntary practice into a comprehensive regulatory requirement for a wide range of companies operating in the EU.

The CSRD applies in phases, as amended by the stop-the-clock Directive (EU) 2025/794 and Omnibus I (Directive (EU) 2026/470): from financial year 2024 for large public-interest entities with more than 500 employees already subject to the Non-Financial Reporting Directive (NFRD); from financial year 2027 for EU undertakings and groups that exceed both EUR 450 million in net turnover and an average of 1,000 employees; and from financial year 2028 for non-EU groups with more than EUR 450 million in EU net turnover, through an EU subsidiary or branch with more than EUR 200 million in turnover. Listed SMEs are no longer in scope.

Companies must report in accordance with the European Sustainability Reporting Standards (ESRS) adopted by the European Commission as delegated acts. The first set of ESRS includes two cross-cutting standards (ESRS 1 and ESRS 2), five environmental standards (covering climate change, pollution, water and marine resources, biodiversity, and resource use/circular economy), four social standards (covering own workforce, workers in the value chain, affected communities, and consumers/end users), and one governance standard (covering business conduct).

Sustainability reports must be included in the management report, published in a machine-readable digital format (XHTML with ESEF taxonomy tagging), and subject to limited assurance by an independent auditor or assurance services provider. The CSRD represents a paradigm shift from voluntary, fragmented sustainability disclosures to standardised, assured, and digitally accessible ESG reporting that is placed on an equal footing with financial reporting.

• CSRD/ESG