Corporate Sustainability Reporting Directive (CSRD)

What is the CSRD?

The Corporate Sustainability Reporting Directive (CSRD) is an EU environmental, social and governance (ESG) standard designed to make corporate sustainability reporting more common, consistent and standardized (including for biodiversity).

  • CSRD came into force in January 2023, and will be rolled out progressively.

  • The first companies required to implement the new rules will have to do so for financial year 2024, for reports to be published in 2025.

  • CSRD will apply to all large EU companies and listed SMEs, as well as companies with activities in the EU.

  • Companies subject to CSRD will have to report according to the European Sustainability Reporting Standards (ESRS), a component of CSRD that outlines the disclosure process.

  • The European Commission adopted ESRS on 31 July 2023. There are twelve ESRS standards covering the full range of sustainability issues. Specifically, ESRS E4 covers the disclosure requirements for biodiversity.

  • All twelve ESRS standards will become law in the EU from 1 January 2024.

When will CSRD and ESRS take effect?

CSRD will take effect in four phases:

  1. Companies already subject to the Non-Financial Reporting Directive (NFRD) must begin using ESRS in FY2024, for reports to be published in 2025.

  2. Large EU companies that are not currently subject to NFRD must begin reporting using ESRS in FY2025, for reports to be published in 2026. A large EU company has at least two of the following:

    • more than 250 employees

    • an annual turnover of more than €40million

    • total assets of €20million

  3. EU-listed SMEs must begin reporting using ESRS in FY2026, for reports to be published in 2027, but can apply for an exception to report from 2028.

  4. International companies with net turnover above €150million in the EU who meet other CSRD requirements must begin using ESRS in FY2028, for reporting in 2029.

Exception for ESRS E4 (Biodiversity and ecosystems)

Companies with fewer than 750 employees don't have to report on ESRS E4 for the first two years of their CSRD reporting.

Working with clients on CSRD and ESRS reporting:

  • Overall gap analysis on the current state of alignment, including recommendations on actions to close gaps and alignment tracking tools for ongoing monitoring

  • Supporting training and awareness on CSRD and biodiversity within
    your organization, including collaboration with teams leading on disclosure (e.g. internal finance, legal or audit teams)

  • Mapping and understanding potential biodiversity risks in your value chain and assessing their materiality

  • Quantifying your biodiversity footprint, using metrics and tools appropriate for your sector and the nature and scale of your activities

  • Preparation and/or independent review of responses to be submitted in line with mandatory timelines

We've led clients on their CSRD journeys spanning a wide variety of sectors:


  • Fashion & textiles
  • Agriculture
  • Infrastructure
  • Technology and media
  • ... and more

Financial Institutions

  • Development banks
  • Commercial banks
  • Asset owners
  • Asset management
  • Impact investors

Your CSRD journey: how we can help

The table below illustrates how we can help your business to leverage the opportunities available at each stage of the CSRD journey through our three-phase approach, with examples of relevant services

  Assessment Strategy Implement & disclose
CSRD steps:

E2 IRO-1

E2 SBM-3, E4.5, E4.6

E4.1, E4.2, E4.3, E4.4

✓ Disclose

What you get:
  • Capacity building workshops

  • Identification & prioritization of significant sites

  • Double materiality assessment

  • Internal readiness preparation (including data collation)

  • Gap analysis

  • Define the state of biodiversity, identify direct drivers of loss and management of impacts in line with CSRD and/or other reporting frameworks (e.g.CDP, GRI, ISSB, SBTN, SFDR, TNFD)

• CSRD-aligned nature strategy and stakeholder engagement

  • Report preparation for public disclosure, information to support audit preparation and roadmaps for future disclosure iterations

  • Defined biodiversity action plans, including KPIs and monitoring in alignment with CSRD

Example service: e.g. Nature Disclosure Readiness e.g. Footprinting services e.g. Impact investment or Strategy services e.g. On the ground support



Will my company’s CSRD disclosure be subject to a third-party audit?

Yes, CSRD will require third-party assurance and external auditing. This is no longer optional, unlike with NFRD. Although we cannot assist you with auditing directly, we are able to support and act as specialist advisors during this process, as needed.

SFDR for financial institutions – what is the relationship between SFRD and CSRD?

The Sustainable Finance Disclosure Regulation (SFDR) is intended to improve transparency for sustainable investment products and sustainability claims made by financial market participants. CSRD, on the other hand, requires organizations to disclose their impacts on social and environmental issues. From 2023, most EU financial institutions and companies will be legally required to disclose financial information through both SFDR and CSRD.

What happens if a company is not compliant with CSRD?

The objective of CSRD is transparency. A company may declare that it does not have the necessary data, but such claims will be checked for credibility and may be challenged. For example, an oil company may not be deemed credible if it claims not to have data on its environmental impact.