• The size of a company is determined by the previous financial year, and category changes are only applied after meeting criteria for two consecutive years.
  
• SMEs without securities on regulated markets are not required to report sustainability, unless they are a parent of a large group.
  
• Credit institutions and insurers must report sustainability if they are large or SMEs listed on regulated markets. Other financial institutions must report sustainability if they meet the legal and size criteria.
  
• Small institutions under NFRD continue to report until 2026; if they are a parent of a large group, they must use full ESRS from 2024 if it is in the public interest or in 2025 in other cases. And a parent company exempt from consolidating financial statements is not required to report sustainability, unless it is a large company.
  
• The average number of employees is calculated with Annual Work Units (AWU), considering full-time, part-time and temporary as fractions.
  

• UCITS and AIFs are exempt from sustainability reporting.
• But companies that manage UCITS and AIFs must report sustainability if they meet the legal and size criteria.
  
• ETFs are exempt if they are UCITS/AIFs.
  
• REITs must report sustainability if they do not meet the AIF classification and are listed on regulated markets.
  
• Pension funds must report sustainability if they are within the scope of the Accounting Directive.
  
• Sustainability reporting is considered regulated information under the Transparency Directive.‍

‍While some funds such as UCITS, AIFs and ETFs are exempt, management companies and other actors, such as REITs and pension funds, have obligations depending on their structure and size. In addition, sustainability reporting plays a key role in market transparency.

• Listed SMEs, small institutions and captive insurers can opt out of sustainability reporting until 2028.
• Consolidated parents are exempt from including Article 19 KPIs, while SMEs may omit individual reports if they comply with the ESRS.
• A subsidiary is exempt from sustainability reporting if it is covered by its parent's consolidated report, subject to specific conditions.
• The parent's report is not required to be available at the time of publication of the subsidiary's report, but must include a future link.
  

• The parent company report must be in a language accepted by the Member State if required by the Member State.
  
• Exempt subsidiaries must clearly state their exemption in the management report and need not follow specific formats unless required by national rules.
  
• Large listed companies cannot use Article 19a exemptions; they are obliged to report on sustainability.

• If a management report is not prepared, the company must publish a separate document that complies with digital requirements.
  
• A company exempt from consolidating financial statements must include relevant financial information in its consolidated sustainability statement.
  
• Simplified ESRS can be used for listed SMEs, small institutions and captive insurers.
  
• ‘Reasonable effort’ means attempting to obtain value chain data with available tools, proxies or average data.
  
• Requests for sustainability information for SMEs will be limited for the first three years.

• The transitional period for value chain disclosure lasts three years from the start of obligations for each company.
  
• Taxonomy regulation disclosures
  some text
  • Companies that fall within the scope of Articles 19a or 29a.
    
  • Sustainability exempt companies must include Taxonomy disclosures if they are not covered in their parent company's consolidated report.
    
  • SMEs that do not report sustainability do not need to include it.
    
• Information provided under the Taxonomy may be included in sustainability if it complies with the ESRS.

• Companies may use estimates for sustainability reporting in the early years, explaining limitations.
• Accounting policies should be included in sustainability reports.
  
• Subsidiaries outside the scope of the CSRD should report sustainability if relevant to the value chain.
  
• ‘Contextual information’ includes data on sustainability risks, opportunities and policies.
  
• Uncertainties in reported data should be disclosed along with plans to improve accuracy.

• Third country parents do not need a specific legal form, only to meet the criteria for significant operations in the EU.
  
• Third country subsidiaries must ensure publication of a consolidated report that complies with the ESRS. Not all subsidiaries are required to publish a sustainability report; a consolidated report at group level is sufficient.
  
• Companies under Article 40a
  some text
  • Must use adopted ESRS or equivalent standards.
    
  • If not all necessary information is collected, limitations and future measures should be disclosed.
    
  • Article 40a reports should be published in the same timeframe as financial reports.

• Digital mark-up should include XHTML and key tags according to Article 29d.
  
• Auditors must meet specific training, experience and professional qualifications.
  
• Statutory auditors approved before 2026 can verify sustainability if they meet additional requirements.
  
• Practical training for auditors must include at least eight months in sustainability.
  
• National authorities monitor the quality of sustainability verifications.
  
• Standards used for auditing include ISAE 3000 or other recognised standards.
  
• The initial level of assurance required is limited, but can be raised to a reasonable level.
  
• Independence of auditors is ensured following the requirements of the Audit Directive.

• If an auditor does not comply with independence, he/she cannot perform verifications and may face sanctions.
• The competence of auditors is ensured by continuous training and specific certifications.
• If Member States do not implement additional requirements, the minimum standards of the Audit Directive apply.
• Published reports must be accessible in business registers or digital platforms.
• Confidential information may be justifiably omitted if it affects competitiveness.
• In case of conflicts between national legislation and ESRS, national legislation is prioritised, explaining deviations.
• Changes to ESRS should be monitored and implemented in a timely manner, with impacts disclosed.
• If not all ESRS are not met in the first years, reasons and plans for improvement should be detailed.
• Historical data should be provided if available; otherwise, their absence should be explained.
• Member States can facilitate compliance by providing training, digital tools and technical support.
• The European Commission oversees implementation by monitoring transposition and issuing recommendations.

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