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Corporate Sustainability Reporting directive (CSRD): EFRAG and the European Commission publish implementation guidance and FAQs

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Executive Summary

The AMF publication announces implementation guidance and FAQs on the Corporate Sustainability Reporting Directive (CSRD) released by EFRAG and the European Commission, aimed at clarifying reporting standards under the European Sustainability Reporting Standards (ESRS). This matters for compliance professionals as it provides actionable tools to meet expanded sustainability disclosure requirements, ensuring audit-ready reporting amid phased rollouts and third-party assurance mandates. It supports harmonized EU-wide compliance for nearly 50,000 companies, enhancing data comparability and investor transparency. #

What Changed

- EFRAG and the European Commission have published specific implementation guidance and FAQs to operationalize CSRD reporting using ESRS, focusing on double materiality assessments, climate disclosures (including Scope 1-3 GHG emissions), and Paris Agreement-aligned transition plans starting in 2025. - CSRD replaces the NFRD with broader scope (quadrupling affected companies to ~50,000), mandatory digital tagging (ESEF/XBRL), limited third-party assurance (phasing to reasonable), and integrated sustainability-financial reporting in management reports. - Recent amendments defer timelines for certain waves, adjust scope thresholds, add exemptions, cap value-chain disclosures, and refine assurance standards. #

What You Need To Do

  • Review EFRAG/EC guidance and FAQs for ESRS implementation; conduct double materiality assessment to identify material ESG topics
  • Map and collect ESG data (GHG emissions Scope 1-3, value-chain impacts) with audit trails; develop Paris-aligned transition plans
  • Integrate sustainability into management reports with digital tagging (XBRL/ESEF); secure limited third-party assurance
  • Strengthen data governance, test processes, and monitor updates from EFRAG/EC/AMF

Key Dates

2025 - First wave (NFRD reporters: large listed/public interest entities >500 employees) publish CSRD reports for FY2024.
2026 - Large EU companies (previously planned for FY2025) deferred to 2028 for FY2027 reporting.
2028 - Listed SMEs report for FY2026 (deferred from 2027).
2029 - Final wave including certain non-EU firms; CSDDD applies from July 26, 2029.

Compliance Impact

Urgency: High - With first reports due in 2025 for ~11,000 firms and preparations critical for 2026+ waves, non-compliance risks enforcement, reputational damage, and investor scrutiny. Deferred timelines offer breathing room but demand immediate data readiness amid evolving standards and assurance mandates.

Who is Affected

Large EU public interest entities (listed companies, banks, insurers) with >500 employees (first wave).Other large EU companies (>250 employees in second wave), listed SMEs (third wave), and non-EU companies with significant EU operations (>€150M turnover).All firms must conduct double materiality assessments; climate standard (E1) applies universally, including Scope 3 emissions.

Summary

Sustainable Finance Periodic & ongoing disclosures Corporate Sustainability Reporting directive (CSRD): EFRAG and the European Commission publish implementation guidance and FAQs

Relevant Firm Types

Asset ManagerBankInsuranceAll Firms
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