Häufig gestellte Fragen
Who falls under the CSRD reporting obligation after the Omnibus changes?
With the Omnibus I package — adopted by the EU Parliament on 16 December 2025 and finally approved by the Council in early 2026 (published in the Official Journal on 26 February 2026) — the scope of the CSRD was significantly narrowed: in future, only companies with more than 1,000 employees and net revenue of over 450 million euros are subject to reporting, instead of the originally envisaged threshold of 250 employees. As a result, many mid-sized companies that would have been covered under the old thresholds fall outside the direct obligation. However, the nationally transposed version is always decisive, which is why companies should individually verify when the rules first apply to them; even companies not directly obligated can be indirectly affected if larger customers request sustainability data from their supply chain.
From when does the CSRD apply and what does the stop-the-clock rule mean?
The reporting obligation is being introduced in stages by company size and was eased in terms of timing by the so-called stop-the-clock directive of April 2025. For the second wave, the original first reporting date was postponed from financial year 2025 to 2027, and for the third wave from financial year 2026 to 2028. The thresholds newly defined in the Omnibus package apply to financial years beginning on or after 1 January 2027, so the first reports under the new rules will be submitted in 2028. Given the still ongoing national transposition, specific deadlines should be re-verified before any planning.
What does double materiality mean in CSRD reporting?
Double materiality is a central principle of the CSRD and is given concrete form by the European Sustainability Reporting Standards (ESRS). It requires companies to consider two perspectives: on the one hand, how sustainability issues affect the company's financial position (financial materiality), and on the other, what impact the company itself has on the environment and society (impact materiality). The resulting materiality assessment forms the basis of the entire report and determines which topics a company must disclose and which it need not. Only topics classified as material must be reported in detail according to the respective ESRS data points.
What data does the ERP system provide for a CSRD report?
Many of the metrics required for the CSRD arise in day-to-day operations anyway and already reside in business systems: energy and fuel consumption in financial accounting as the basis for Scope 1 and Scope 2 emissions, material quantities in materials management, and supplier and workforce metrics for social disclosures. For Scope 3 emissions along the value chain, additional data from suppliers is required, which the ERP alone does not cover. Since CSRD reports are subject to mandatory assurance, the origin and changes of the figures must be traceable via an audit trail and well-maintained master data. However, ERP systems rarely cover the required ESRS data points completely and are often combined with specialised ESG tools via interfaces.
Does a CSRD report have to be externally audited?
Yes, the sustainability report under the CSRD is part of the management report and is subject to a mandatory external assurance requirement, set at the level of limited assurance. This review by an auditor or accredited assurance provider makes the data quality and traceability of the reported metrics decisive, as unverifiable figures can be challenged. The report must also be provided in a machine-readable format with digital tagging, which presupposes a clean, structured data basis. Audit-proof source systems and consistent master data therefore move to the centre of preparation.
Do I need a dedicated sustainability or ESG tool for the CSRD?
Whether a dedicated tool is necessary depends on the scope of the reportable topics and the complexity of the data situation. With limited requirements, existing ERP modules and spreadsheet solutions can suffice, while extensive ESG reporting with many ESRS data points and Scope 3 data collection usually makes specialised tools worthwhile. With the revised ESRS, the number of mandatory data points was reduced considerably, which lowers the effort for many companies; a voluntary standard (VSME) is also available for companies without a reporting obligation. What is decisive for tool selection is that the data basis is clean, exportable and connectable via documented interfaces, rather than requiring expensive custom solutions.