CSRD guide 2025-2026: obligations, deadlines and ESRS

Table of contents

What is the CSRD Directive and why it changes the game

Which companies are required to report under CSRD

Implementation calendar: when CSRD comes into force

ESRS standards: the technical framework for ESG reporting

What practical information needs to be reported

How to prepare for CSRD compliance

Official tools and resources for implementation

Additional resources to go deeper on CSRD, ESRS and sustainability reporting

Why Dcycle is the most efficient solution for CSRD compliance

Frequently Asked Questions (FAQs)

The CSRD Directive (Corporate Sustainability Reporting Directive) has arrived to completely change the way European companies report their sustainability information.

And no, it’s not just another regulation. It’s the new ESG transparency standard that will affect more than 50,000 companies in the EU and establishes requirements as rigorous as those for financial information.

If your company meets certain size criteria or is publicly traded, it’s very likely that you are already (or soon will be) required to report under CSRD and the ESRS standards. And if it doesn’t directly affect you yet, your key clients or suppliers will ask you for ESG data to comply with their own obligations.

In this post we explain everything you need to know about CSRD in 2025 and 2026: which companies are obligated, what the application deadlines are, what information needs to be reported, and how the ESRS standards structure the entire process.

Because today, sustainability is not optional. It’s measurable, auditable, and strategic. And complying with CSRD efficiently can make the difference between lagging behind regulation or turning it into a competitive advantage.

What is the CSRD Directive and why it changes the game

Directive (EU) 2022/2464, known as CSRD, establishes new mandatory sustainability reporting requirements for thousands of companies in Europe.

Its objective is clear: to elevate corporate transparency on ESG (environmental, social, and governance) matters to the same level of rigor as financial information.

What CSRD requires companies to do

Companies covered by the directive must:

Publish an annual sustainability report integrated into their management report
Follow the European ESRS standards (European Sustainability Reporting Standards)
Submit the report to external verification by an independent auditor (limited assurance audit)
Present information in digital XHTML format with data tagging, to facilitate accessibility and analysis by investors and regulators

The principle of double materiality

One of the key concepts of CSRD is double materiality, which requires companies to assess ESG matters from two perspectives:

Impact materiality: how the company’s activities affect society and the environment
Financial materiality: how ESG matters represent risks or opportunities for the company itself

This means that measuring environmental footprint is not enough. You also need to analyze how climate change, social risks, or governance aspects can affect the company’s financial performance and strategy.

Which companies are required to report under CSRD

CSRD dramatically expands the number of companies required to report sustainability. It no longer only affects large listed corporations, but a much broader spectrum of organizations.

Large companies (the bulk of those obligated)

All companies that meet at least two of these three criteria are obligated:

≥ 250 employees (average workforce)
≥ 40 million € in net turnover annually
≥ 20 million € in total assets on the balance sheet

These conditions define “large companies” in the EU, including both private and listed companies. It’s estimated that around 50,000 companies in the EU fall within this scope.

Listed companies (including SMEs)

All companies listed on EU regulated markets will be subject to CSRD, regardless of their size (except micro-enterprises).

This includes listed SMEs, although certain reliefs and simplified standards are provided for them.

Third-country companies with EU presence

The directive also reaches non-European business groups with substantial activities in the EU.

Specifically, any company from a third country that:

Generates more than 150 million € annually in revenues in the EU, and
Has at least one large or listed subsidiary in the EU (or a branch with >40M€ in business)

…must prepare a consolidated sustainability report of its EU operations according to CSRD standards.

Implementation calendar: when CSRD comes into force

CSRD implementation is phased, with different dates depending on the type and size of company. Here’s the updated calendar after the 2025 modifications:

Phase 1: Large public interest companies (already in force)

Affected companies: Large listed or financial companies with >500 employees (already subject to the previous NFRD directive)

First covered fiscal year: 2024
Publication of first report: 2025

These companies are already reporting under CSRD since fiscal year 2024.

Phase 2: Other large companies (POSTPONED)

Affected companies: Other large EU companies (≥250 employees, ≥€40M turnover, ≥€20M assets)

Original calendar: Fiscal year 2025 (report in 2026)
Revised calendar after “stop-the-clock”: Fiscal year 2027 (report in 2028)

The “stop-the-clock” Directive approved in April 2025 postponed the entry into force by two years for these companies, giving them more preparation time.

Phase 3: Listed SMEs (POSTPONED)

Affected companies: Small and medium-sized companies listed on regulated markets (excluding micro-enterprises)

Original calendar: Fiscal year 2026 (report in 2027)
Revised calendar: Fiscal year 2028 (report in 2029)

Listed SMEs also benefited from the two-year postponement and will be able to use a simplified standard (VSME).

Important note: There are proposals under negotiation (Omnibus I) to exclude companies between 250 and 1,000 employees from the mandatory scope, but as of late 2025 these modifications are not yet in force.

Phase 4: Third-country companies

Affected companies: Non-EU groups with revenues >€150M in the EU and significant subsidiaries/branches

First covered fiscal year: 2028
Publication of first report: 2029

This calendar remains unchanged from the original plan.

ESRS standards: the technical framework for ESG reporting

To comply with CSRD, companies must report following the European Sustainability Reporting Standards (ESRS) developed by EFRAG (European Financial Reporting Advisory Group).

ESRS are a set of technical standards that specify in detail what ESG information must be disclosed and how. Their objective is to standardize reporting in the EU, providing comparability and rigor.

ESRS structure: 12 standards in total

The first set of ESRS consists of 12 standards, divided into two categories:

Cross-cutting standards (2 general standards)

ESRS 1 – General Requirements: Defines how to perform the double materiality assessment and other reporting principles that all companies must follow.

ESRS 2 – General Disclosures: Specifies mandatory disclosures on sustainability governance, business model, strategy, materiality processes, policies, and management systems.

These two standards establish the common basis that all companies must comply with, regardless of their sector or specific situation.

Topical standards (10 specific standards)

The 10 topical standards cover environmental, social, and governance areas. Companies must apply them only if they consider the topic material after their double materiality analysis.

Environmental Standards (ESRS E1 to E5):

ESRS E1 – Climate Change: Mitigation and adaptation, GHG emissions (scopes 1, 2, 3), energy consumption, decarbonization strategies, and climate transition plans
ESRS E2 – Pollution: Air, water, and soil pollution; pollutant emissions, hazardous substance management
ESRS E3 – Water and marine resources: Water extraction and consumption, discharges, impact on marine resources
ESRS E4 – Biodiversity and ecosystems: Impact on biodiversity, habitat loss, ecosystem services
ESRS E5 – Circular economy: Raw material use, waste generated, recycling and reuse strategies

Social Standards (ESRS S1 to S4):

ESRS S1 – Own workforce: Working conditions, wages, health and safety, training, equality, diversity, gender pay gap
ESRS S2 – Workers in the value chain: Working conditions and human rights of suppliers and contractors
ESRS S3 – Affected communities: Impact on local communities, respect for economic, social, and cultural rights
ESRS S4 – Consumers and end-users: Product safety, data protection, responsible marketing, accessibility

Governance Standards (ESRS G1):

ESRS G1 – Business conduct: Corporate culture, ethics, prevention of corruption and bribery, whistleblower protection, business partner relations, lobbying, animal welfare

Flexibility based on materiality

Companies can omit information from a standard if they conclude the topic is not material, although they must briefly explain that conclusion.

The only significant exception is ESRS E1 (Climate Change): if considered non-material, an explicit and detailed justification is required.

Relief measures for the transition

To facilitate adoption, the regulation provides for gradual phases in the first years:

Companies with <750 employees can omit Scope 3 emissions and certain workforce data in their first year
In the first two years, companies can omit detailed information on biodiversity (E4) and workers in the value chain (S2)
During the first year, qualitative descriptions of anticipated financial effects of climate change are allowed

What practical information needs to be reported

Under CSRD, companies must collect a wide variety of quantitative and qualitative data on their ESG impacts, risks, and performance. Let’s see what each dimension includes:

Environmental Dimension: your footprint and approach to environmental sustainability and environmental management

Emissions and climate:

GHG emissions detailed by scopes (1, 2, and 3)
Energy consumption and energy efficiency measures
Climate neutrality transition strategy
Analysis of climate risks and opportunities (aligned with TCFD)

Pollution and resources:

Pollutant emissions to air and water discharges
Hazardous waste management
Water resource use (extraction, recycling, impact on basins)
Percentage of reused or recycled materials

Biodiversity:

Operations in or near protected areas
Impact on ecosystems and species (deforestation, land use)
Restoration or compensation initiatives

Examples of specific indicators: Tons of CO₂ emitted, carbon footprint per revenue unit, energy intensity, volume of recovered waste, water consumption by source.

Internal labor practices:

Number of employees (broken down by contract type, gender, location)
Equality and diversity policies (women in management, gender pay gap)
Training and professional development (training hours)
Occupational health and safety (accident rates)
Working conditions (schedules, work-life balance, living wage)

Supply chain:

Supplier monitoring on labor rights
Audits of critical suppliers
Prevention of child labor and forced labor
Safe conditions and living wage in the chain

Local communities:

Impacts of operations on communities
Social investments and public consultations
Management of displacements or impacts

Customers and consumers:

Product and service safety
Personal data protection and cybersecurity
Responsible advertising
Access for vulnerable groups

Examples of indicators: Employee injury rate, proportion of critical suppliers evaluated on social matters, number of customer complaints related to privacy.

Governance Dimension: ethics and transparency

Sustainability governance:

ESG governance structure and roles (committees, responsible persons)
Frequency of Board discussions
ESG competencies of management
Linking management remuneration to ESG objectives

Corporate ethics:

Anti-corruption and anti-bribery policies
Code of ethics and compliance training
Internal controls to prevent fraud
Detected corruption incidents and investigations

Integrity and transparency:

Confidential whistleblowing channels
Whistleblower protection
Tax policy and country-by-country reporting
Lobbying activity and political contributions

Third-party management:

Supplier ethics monitoring
Anti-corruption practices in contracts with third parties
Average payment times to suppliers

How to prepare for CSRD compliance

Complying with CSRD is not a one-time procedure, it’s a structural change in how companies manage and communicate their ESG information. Here are the keys to prepare:

1. Conduct a double materiality analysis

The first step is to identify which ESG topics are material for your company from both perspectives (impact and financial).

This analysis will determine which ESRS standards you must apply in depth and allows you to prioritize data collection efforts.

2. Map and centralize ESG data sources

You need to identify where the data is (ERP systems, CRM, spreadsheets, suppliers) and establish processes to consolidate it in an automated and traceable way.

This is where a platform like Dcycle makes the difference. Instead of working with multiple dispersed tools, we centralize all ESG information in a single system that:

Integrates directly with your data sources
Automates collection and normalization
Keeps data updated in real-time
Ensures complete traceability for audits

3. Implement automated reporting systems

The days of manually compiling ESG reports are over. You need a solution that:

Automatically generates reports according to applicable ESRS
Adapts the format to each standard (CSRD, but also SBTi, EU Taxonomy, ISOs)
Guarantees coherence and consistency in information
Prepares the required XHTML digital format with tagging

4. Prepare for external verification

Remember that the CSRD report must be audited by an independent third party. This means your data must be:

Documented: with clear evidence of each metric
Traceable: with a complete audit trail
Verifiable: with internal quality control processes

5. Train teams and assign responsibilities

ESG management is not just for the sustainability department. It involves:

Legal and compliance
Finance and accounting
Human resources
Operations and supply chain
General management

Everyone must understand their responsibilities in collecting and validating ESG data.

Official tools and resources for implementation

The EU and technical bodies have developed multiple resources to facilitate compliance:

Official documentation and technical guides

CSRD Directive text and the ESRS Delegated Act (available on Eur-Lex)
EFRAG implementation guides (Implementation Guidance) on:
- IG 1: How to perform the materiality assessment step by step
- IG 2: How to collect value chain data
- IG 3: Complete inventory of datapoints required by ESRS
Q&A platform from EFRAG/Commission for frequent questions

Simplified standards for SMEs

The European Commission issued in 2025 a Recommendation for a voluntary SME standard (VSME): a simpler and more proportionate framework that SMEs can use voluntarily.

Listed SMEs can use it as preparatory guidance before their mandatory entry into force.

Technological tools

XBRL digital taxonomy for ESRS: allows electronic tagging of each data point
ESEF platform (European Single Electronic Format): now incorporates sustainability tags
Corporate reporting software with integrated ESRS templates

National regulator communications

Bodies such as CNMV and ICAC in Spain have published guidance communications, FAQs, and guidelines for auditors on how to address CSRD.

Additional resources to go deeper on CSRD, ESRS and sustainability reporting

If this guide works as your high level framework, the next step is execution: confirming whether CSRD applies, deciding what to report, aligning with ESRS, staying on top of 2025 changes, and preparing digital reporting that is consistent and auditable.

Below you have a curated set of complementary resources that expand each critical area, with a practical angle focused on common pitfalls, key decisions, and how to structure the work so you do not waste months on low impact tasks.

The starting point is always scope.

Many teams move too fast into templates and data requests, only to discover later that the company falls under different timing, thresholds, or consolidated reporting rules than they assumed.

Before building anything, validate the perimeter with CSRD obligated companies, which helps you clarify who is in scope, what triggers the obligation, and how to interpret the criteria in a realistic way. Once you know you are in scope, it is also useful to strengthen your understanding of what “CSRD reporting” means beyond the headline.

The obligations are not just about publishing a document, they reshape how you manage governance, traceability, and evidence across the organisation.

That leads to the next common mistake: thinking the deliverable is purely editorial.

Under CSRD, a “report” is inseparable from the system that produces it. If you want a clear operational view of what is expected and what changes compared to older sustainability disclosures, read mandatory sustainability report.

It helps you see the reporting effort as a cross functional program, not as a year end communication exercise.

This framing matters because it affects timelines, internal ownership, and the way you design data collection from the start.

Once the perimeter is clear, the core methodological engine is double materiality. Doing it as a box ticking exercise usually creates a domino effect: irrelevant disclosures, unmanageable data gaps, and a report that is hard to defend when challenged.

To structure the analysis properly and connect impacts, risks and opportunities to what must end up in the report, use CSRD double materiality.

In practice, a good double materiality process becomes a prioritisation tool. It reduces noise, prevents over reporting, and gives you a logical foundation for deciding which ESRS topics, metrics and narratives you actually need.

On top of that, 2025 introduces moving pieces that you should not ignore if you are designing your roadmap now.

The danger is either under reacting and missing an update that changes what you should prepare, or over reacting and rebuilding everything unnecessarily.

To understand what has changed and how it may affect companies reporting under CSRD, review ESRS changes 2025 and what the quick fix means.

Use it to separate changes that affect content from those that affect structure or sequencing, and to adjust your plan without improvising.

Another critical block is the relationship between CSRD and the EU Taxonomy.

Many organisations treat them as parallel streams, which often results in duplicated work, inconsistent definitions, and numbers that do not reconcile across frameworks.

If you want a more integrated approach, this resource helps connect the dots: Dcycle and the EU Taxonomy: how to accelerate regulatory compliance.

The practical takeaway is that you should design shared data foundations and traceability early, because both CSRD and Taxonomy depend on consistent activity classification, evidence, and defensible calculations.

As you mature the project, digital reporting becomes unavoidable. CSRD pushes sustainability reporting toward formats that are more structured, more comparable, and easier to review at scale.

That is why it is worth understanding the implications of report XBRL. You do not need to be technical to benefit from this.

The key is to realise that digital tagging and structured reporting can change how you build your internal process, how you manage source data, and how you keep consistency across reporting cycles.

If you account for this early, you avoid ending up with a narrative heavy report that is painful to convert into robust, repeatable outputs.

In Spain, it is also useful to monitor official signals because they influence interpretation, expectations, and how companies approach evidence and governance in the early years of CSRD. For context on the local regulatory conversation, see official CSRD communication from ICAC and CNMV.

This can help you avoid relying only on generic EU level summaries without considering how the Spanish environment frames the topic, especially when it comes to documentation and defensibility.

If your focus is to accelerate implementation, tooling can play a role, but software selection is often noisy.

Not every ESG tool is suitable for CSRD grade reporting, because CSRD requires stronger structure, traceability, and governance than many “nice dashboard” platforms provide.

To compare options from a capability perspective, use best CSRD software. Treat it as a checklist of what you should expect from a solution: data capture, workflows, controls, auditability, ESRS alignment, and outputs that support reporting rather than just visualisation.

The goal is not to buy tools for the sake of it, but to reduce coordination cost and improve the repeatability of your process.

A different confusion point is mixing CSRD with related frameworks.

Teams often blend “reporting” and “due diligence” discussions, which can derail ownership and sequencing. To keep the boundaries clear, read CSDDD vs CSRD.

Understanding what each framework is for, and how they can complement each other, helps you avoid building a system that conflicts with itself or assigns responsibilities in a way that does not scale.

Finally, when you are in execution mode, the highest value content is the one that helps you prioritise and reduce uncertainty. If you want a practical way to translate requirements into an implementation approach, use effective CSRD regulations.

If you are getting blocked by recurring doubts, misinterpretations, or edge cases, CSRD clarifications is a useful companion to resolve ambiguity without inventing your own rules.

And if you need a clean order of operations to structure the programme, especially when resources are limited, rely on how to prioritise the CSRD directive, which helps turn “we must comply” into a sequenced plan with owners, dependencies, and concrete deliverables.

Used together, these resources move you from “understanding CSRD” to “executing CSRD”.

They help you validate scope, run double materiality properly, adapt to ESRS changes, align CSRD with the EU Taxonomy, prepare for structured digital reporting in XBRL, interpret local regulatory guidance, choose tooling with criteria, distinguish CSRD from CSDDD, and prioritise the work so progress is real, measurable, and repeatable.

Why Dcycle is the most efficient solution for CSRD compliance

When we talk about implementing CSRD, the difference between complying on time or being late is not only in understanding the regulation, but in having the right infrastructure to manage the data.

And that’s where Dcycle stands out as the most agile and automated alternative.

One platform, all standards

We are not consultants who help you occasionally. We are a complete SaaS platform that:

Centralizes all your ESG data in a single system
Automates collection from your data sources (ERP, CRM, spreadsheets)
Structures information automatically to comply with CSRD, ESRS, SBTi, EU Taxonomy, ISOs…
Generates audit-ready reports without manual processes

Ready for CSRD from day one

While other solutions require complex implementations or custom developments, with Dcycle:

You’re operational in a matter of minutes
You don’t need constant external consulting
All departments work on the same reliable database
Data is always updated and traceable

Beyond compliance: strategic sustainability

CSRD shouldn’t just be a formality. We help you turn ESG data into a competitive advantage:

Anticipate future regulations
Improve your operational performance based on real data
Strengthen your position with investors, clients, and administrations
Make strategic decisions with reliable information

In summary: if you don’t measure well, you can’t comply well. And if you don’t comply with agility, you lose competitive advantage.

With Dcycle, ESG management stops being a burden and becomes a business lever.

Frequently Asked Questions (FAQs)

Is my company required to report under CSRD?

You are obligated if you meet at least two of these criteria:

≥ 250 employees
≥ 40 million € in annual turnover
≥ 20 million € in assets

Also if you are a listed company (including listed SMEs, except micro-enterprises) or if you are a non-EU group with >150M€ in EU revenues and significant subsidiaries/branches.

When do I have to start reporting?

It depends on your category:

Large listed companies (>500 employees): Already since 2024 (report in 2025)
Other large companies: Fiscal year 2027 (report in 2028) after postponement
Listed SMEs: Fiscal year 2028 (report in 2029)
Third-country companies: Fiscal year 2028 (report in 2029)

What happens if I don’t comply with CSRD?

Non-compliance can result in:

Administrative sanctions from national regulators
Loss of access to financing (many investors and banks require ESG compliance)
Significant reputational damage
Exclusion from public tenders (increasingly linked to ESG criteria)

Do I need an external audit of the CSRD report?

Yes, it’s mandatory. The sustainability report must undergo verification by an independent auditor or reviewer, with at least a limited assurance level (similar to a limited review of financial statements).

Can I use a simplified standard if I’m an SME?

Listed SMEs will eventually be able to use the voluntary VSME standard (more simplified), although they must comply with the complete ESRS unless there are future regulatory changes.

Non-listed SMEs are not obligated by CSRD, but can use VSME voluntarily if they wish (or if their clients request it).

How does CSRD relate to other frameworks like GRI or SASB?

ESRS have been designed to be interoperable with other international frameworks (GRI, SASB, TCFD, GHG Protocol). In many cases, if you already report under GRI or SASB, you’ll have much of the work advanced.

However, ESRS are more comprehensive and have specific requirements (such as double materiality and digital format) that other frameworks don’t require.

What data is most difficult to obtain for CSRD?

The areas that usually present the most challenges are:

Scope 3 emissions (complete value chain)
Supplier data on social and environmental aspects
Biodiversity impacts (requires geospatial analysis)
Anticipated financial effects of ESG risks
International subsidiary data if not centralized

That’s why it’s essential to have a platform that automates collection and allows managing the complexity of multiple sources.

Can Dcycle help me comply with CSRD?

Absolutely. Dcycle is specifically designed to:

Centralize all your ESG data automatically
Structure information according to ESRS without manual work
Generate audit-ready CSRD reports
Maintain complete traceability of each data point
Scale as your ESG maturity grows

You don’t need external consultants or custom developments. With Dcycle, you have total control of your ESG information from day one.