CSRD

Home Services Financial Advisory Reporting & Regulatory ESG Solutions CSRD

CSRD

OMNIBUS PACKAGE

SERVICES

CONTACT

ROADMAP

FAQ

CSRD (Corporate Sustainability Reporting Directive)

The EU establishes a legal framework for sustainability and responds to opposition to the sustainability agenda: In 2014, the EU created a policy framework to require companies to take greater responsibility toward society and the environment. The so-called CSR Directive was the first reporting requirement in the area of non-financial information (NFS). In 2017, this EU directive was transposed into German law, and large capital market-oriented companies and financial institutions were required by the CSR Directive Implementation Act to include a non-financial statement in their management report.
Subsequently, at the end of 2019, the European Green Deal marked another milestone, with the goal of achieving climate neutrality by 2050. As part of this effort, the CSR Directive was revised and the EU Taxonomy was approved.

Sustainability

EU taxonomy

As part of the 2015 UN Climate Change Conference, the Paris Climate Agreement was agreed with the aim of achieving climate neutrality by 2050. In order to achieve this goal, the EU has drawn up the “Financing Sustainable Growth” action plan. The EU taxonomy is a core component of this action plan and is intended to contribute to the sustainable transformation of the economy.

Learn more

On February 16, 2022, the CSRD was adopted at the European level. The CSRD was subsequently to be transposed into national law by all member states by July 6, 2024. Once transposed, affected companies are required to report in accordance with the ESRS published by EFRAG. The goal was to establish an initial reporting requirement under the CSRD for capital market-oriented companies with more than 500 employees for the 2024 fiscal year (the so-called first wave), followed by large corporations (the so-called second wave) and capital market-oriented SMEs (the so-called third wave). However, the directive has not yet been transposed into German law, meaning that capital market-oriented companies and groups in Germany must continue to issue non-financial statements in accordance with the old CSR Directive.

Implementation of the Omnibus Package

On February 26, 2025, the European Commission published the omnibus packages, which were also adopted by the EU Council on February 24, 2026. For the CSRD, this entails, in particular, adjustments to the thresholds, the effective dates, and the scope of reporting. CSRD reporting applies only to companies with more than 1,000 employees and more than EUR 450 million in net revenue.
The Omnibus Package introduces changes to the scope of reporting across six optimization levers, as well as to the first-time application date through the “stop-the-clock” provision. If you would like to know how these changes will affect your company, please contact us for a no-obligation consultation.

Omnibus Package: Changes to the Scope of Reporting

As part of the Omnibus Initiative, the European Commission tasked EFRAG with revising the ESRS. A delegated act is expected to be approved by mid-2026, meaning the revised ESRS would apply starting with the 2026 reporting year. EFRAG’s current draft proposes six key areas for improvement, including significant simplifications in the dual materiality analysis, value chain data, a reduction in mandatory data points, and enhanced comprehensibility, clarity, and accessibility.

Simplification of the Double Materiality Analysis (DMA)

Top-Down Approach: The Business Model as the Central Starting Point
Introduction of the “Materiality of Information” Concept & Fair Presentation Principle
“Sub-Sub-Topics” removed from the topic list (AR16 List) and sub-topics revised
New guidance on gross and net considerations

Improved readability / conciseness of the sustainability report

Optional use of summaries
(Executive Summary)
Option for disclosures in the notes (e.g., EU taxonomy)
Consistent, structured, topic-specific standards

Linking Agnostic and Topic-Specific Standards

MDRs renamed GDRs and simplified
Significant harmonization and simplification of reporting requirements for policies, actions, and targets (PATs)
Flexibility in choosing the reporting level for key topics

Comprehensibility, clarity, and accessibility

The number of required data points has been reduced from 57% to 61%
Voluntary “may” data points have been listed separately under NMIG (Non-Mandatory Illustrative Guidance)
Many of the deletions result from the removal of redundancies
New principles-based approach of the standard
The internal risk management system must be taken into account in the DMA; consistency should be ensured

General relief measures

“undue cost or effort” regarding the identification of IROs, the supply chain, and data collection
Consolidation scope = financial scope
Through 2029 (FY 2026 for companies in the first wave) Phase-in relief for quantitative disclosures regarding expected financial impacts, substances of concern (SoC), as well as E4, S2, S3, and S4

Improved interoperability with global reporting standards

Greater alignment with the language and content of the global (ISSB) standards

Services within the scope of the CSRD

Conducting, updating, and validating the materiality analysis, including workshops to identify and assess impacts, risks, and opportunities

Gap analysis of the ESG KPIs collected to date and the key ESRS topics

Development of an ESG strategy in accordance with ESRS guidelines

Implementation of ESG processes for data collection, including the necessary internal controls

Report design and preparation, including audit-proof documentation

Data Monitoring & Data Optimization

Your contacts for CSRD

Natalie Wurms

Partner Advisory

München

+49 170 1163863

Natalie.Wurms@wts.de

Michèle Färber

Partner Advisory

München

+49 170 2053099

Michele.Faerber@wts.de

to profile

ESG Discovery - your introduction to the ESG transformation!

Can't see the wood for the trees? No matter how complex your ESG challenges are, we analyze and structure them together with you and accompany you step by step on your way to more sustainability and CSRD-compliant and audit-proof reporting. Get started now with ESG Discovery with our in-house start-up aid for your entry into the ESG transformation.

Concentrated ESG expertise, compactly packaged in solution-oriented workshop formats: whether materiality analysis, ESRS implementation, EU taxonomy, ESG strategy, ESG ICS, green finance or ESG data value creation, together with our interdisciplinary team of ESG experts, we offer modular workshops that are perfectly tailored to your individual needs and challenges. Your company is unique - your workshop should be too.

If you don't know where to start: We are happy to guide you through the current regulatory requirements, latest industry trends and best practices on the topics that are relevant to you. We break down the plethora of information on the ESG topics relevant to your company to the essentials and make it available to you in the form of action-oriented work packages.

Ready, set - go! As a result of our ESG Discovery Workshops, you will receive an ESG roadmap with a tangible and clearly prioritized ESG agenda for your company. From the quick wins to the really big steps: start your ESG transformation with us!

Are you interested in an initial consultation on the ESG Discovery Phase to gain an insight into the range of our ESG solutions? Please don't hesitate to contact us!

Request a non-binding consultation

Frequently Asked Questions About CSRD

What is meant by double materiality?

The concept of double materiality represents a significant change in the CSRD compared to the NFRD. According to the CSRD, a company must consider sustainability aspects from two perspectives: the outside-in and the inside-out perspectives. The inside-out perspective focuses on analyzing the impacts the company has on the environment and people, such as the greenhouse gas emissions it generates. The outside-in perspective, on the other hand, addresses risks and opportunities—that is, the financial effects that may arise from sustainability issues affecting the company. For example, a location near a flood-prone area constitutes an outside-in risk. As part of the materiality analysis, both the inside-out perspective (materiality of impacts) and the outside-in perspective (financial materiality) must be analyzed. According to the CSRD, an issue is material if it is relevant from either the outside-in or the inside-out perspective and does not, as with the NFRD, need to be relevant from both perspectives.

How are the CSRD and the ESRS related?

The CSRD requires companies to report and establishes key parameters such as the scope of affected companies, the effective date, and audit requirements. As part of the CSRD, the European Commission tasked EFRAG (European Financial Reporting Advisory Group) with developing uniform reporting standards, the ESRS. The ESRS describe in detail what information must be reported and how, as well as the methodology companies must follow in doing so.

What is the Omnibus Package?

The EU Omnibus Package, presented in the spring of 2025, aims to revise regulations in the ESG area—specifically the CSRD (reporting), CSDDD (supply chains), and the EU Taxonomy (classification system)—reduce the bureaucratic burden on companies, and provide relief through temporary deferrals (“Stop the Clock”). Specifically, the thresholds for sustainability reporting will be raised (companies with more than 1,000 employees and revenue exceeding 450 million euros), the start of reporting obligations for large unlisted companies will be postponed to the 2027 fiscal year, the due diligence requirements of the CSDDD will be extended to even larger companies (5,000 employees and €1.5 billion in revenue, with a focus on direct suppliers and a postponement to July 2029), and overlaps between the various ESG frameworks will be harmonized to avoid redundancies.

What level of assurance is required for non-financial reporting?

A mandatory limited assurance audit is required for the reports. In the future (expected to begin in 2028), the European Commission may decide to require a reasonable assurance audit as well.

What was the basis for the development of the ESRS? How was the ESRS developed?

EFRAG was tasked by the European Commission with developing the ESRS to ensure consistency and standardization in sustainability reporting across the EU. The delegated act on the first set of ESRS was officially adopted on July 31, 2023. The amendments proposed as part of the omnibus package are expected to be finalized and implemented by mid-2026 through a delegated act.

To what extent should internal processes be adjusted?

Following the materiality analysis, companies should establish processes to collect ESG data across the entire organization. One effective approach is to integrate ESG criteria into reporting processes. Furthermore, the internal control system and corporate governance should be adapted to address the identified ESG risks.

Further topics you could be interested in

EU taxonomy

ESG Solutions

VSME

ESG Discovery Phase

Contact us today

Do you have any questions about our services or WTS? Please let us know. Please fill in our short contact form. We will get in touch with you as soon as possible.

Contact