UPDATE: CSRD Law Requires Companies to Report (Multiple) Impacts in Coming Year(s)

ESRS approved for what to report and how

· EU,Disclosure

Type: Disclosure of ALL Material Impacts (water, emissions, etc.)

Jurisdiction: Europe


EU law now requires all large companies and all listed companies (except listed micro-enterprises) to disclose information on what they see as the risks and opportunities arising from social and environmental issues, and on the impact of their activities on
people and the environment.

CSRD Timeline (current but subject to change):

  • January 2024: All companies already subject to the Non-Financial Reporting Directive (reporting in 2025 on 2024 data) Listed on EU Stock exchange.
  • January 2025: Large EU companies not currently subject to the Non-Financial Reporting Directive (reporting in 2026 on 2025 data)
    “Large” EU companies that are not listed:
  • Greater than €25 million balance sheet total
  • Greater than €50 million net turnover
  • Greater than 250 employees.
  • January 2026: Listed small and medium-sized enterprises, (reporting in 2027 on 2026 data).
  • January 2028: Non-EU companies doing business in Europe (reporting in 2029 on 2028 data)
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*CSRD will require data equivalent to LCAs via ESRS rules.

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FDRA Suggested Kickstart Strategy (Oct 2023):

1. Build your ESG data collection system (key person or team, software)

  • start to collect key data listed in the coming regs from suppliers. Designate someone in charge of data collection.
  • ask suppliers for data that is specially listed by the EU rules. GHG data collected here can also be used for other jursdictions like California (think of a matrix).
  • ensure you have a central point of truth to put all the data in. *PLM or cloud excel.
  • GHG is the minimum. You will need LCA data due to multitute of impacts to report.
  • *You need to learn how to read LCAs and prepare your suppliers to provide them.
  • *There are not ‘targets’ but you must report accurate data
  • Prepare budget to hire a firm to take your data and report for you.

2. Codify your strategy

  • CSRD reporting requires you to tell what your strategy is to reduce impacts.
  • You can list specific materials, processes and such that you are leaning into.
  • If you argue something is not ‘material’ to your company, you must explain why,
    and *someone may challenge the notion that something even ancillary to your
    business doesn’t cause an impact.