CSRD Report 2025: What companies need to know now

What is a CSRD report?

The CSRD report is the central element of the new EU directive on sustainability reporting, the Corporate Sustainability Reporting Directive (CSRD). It replaces and significantly expands the previously applicable Non-Financial Reporting Directive (NFRD ): more companies must report - and at a significantly higher level.

The CSRD requires the disclosure of sustainability information in the areas of environmental, social and governance (ESG). In contrast to the NFRD, this information must be provided in accordance with binding standards, the European Sustainability Reporting Standards (ESRS), and must be audited externally.

Large companies will initially be affected from the 2024 financial year, followed by capital market-oriented SMEs from 2026. Many smaller companies will also be indirectly obliged to be transparent due to supply chain requirements.

A central concept of the CSRD report is dual materiality: companies must analyze and disclose both their impact on the environment and society as well as the risks and opportunities posed by sustainability issues for their own business model.

Deadlines and obligations according to company size

Since the EU omnibus package of February 2025, the CSRD reporting obligation has been introduced gradually and in some cases with a delay. The aim is to ease the burden on smaller companies and reduce the administrative burden. The following periods currently apply:

• Large companies (more than 500 employees):
  Reporting obligation for financial years from 2024 (unchanged)
• Second wave (originally from 2025):
  Reporting obligation postponed to financial years from 2027
• Third wave (including listed SMEs):
  Reporting obligation postponed to financial years from 2028

The group of users has also been significantly reduced: In future, only large corporations with more than 1,000 employees and additionally at least one of the following criteria will be required to report:

• Balance sheet total over 25 million euros
• Turnover of more than 50 million euros

This means that around 80% of the companies originally affected will no longer be required to report in future. However, many SMEs can voluntarily report in accordance with the VSME standard or are nevertheless motivated to be transparent by supply chain requirements.

Note: These changes originate from the first part of the CSRD Omnibus Regulation, which came into force on April 17, 2025. The member states have until December 31, 2025 to transpose them into national law.

The omnibus package: what has changed in 2025?

In February 2025, the EU adopted key changes to the CSRD reporting obligation with the so-called Omnibus Package. The aim was to ease the burden on small and medium-sized enterprises (SMEs) and reduce the administrative burden.

The most important changes at a glance:

• Phased introduction: the reporting obligations for the second and third waves have each been postponed by two years. Large companies (over 500 employees) will continue to be required to report from 2024, with the next stage following from 2027 and listed SMEs from 2028.
• Reduced group of users: In future, only large corporations with more than 1,000 employees and certain turnover or balance sheet limits will be required to report.
• Voluntary reporting for many SMEs: Around 80% of the companies originally affected are now exempt from the obligation, but can report voluntarily in accordance with the VSME standard or continue to be motivated to be transparent by supply chain requirements.
• Transposition into national law: Member states must transpose the changes into national law by December 31, 2025 at the latest.

Companies should closely examine the new deadlines and thresholds and adapt their reporting strategy accordingly. The omnibus package offers the opportunity to prepare for the requirements of the CSRD in a more targeted manner and with more lead time.

How to create a strong CSRD report

A successful CSRD report is not created overnight. It is a multi-stage process that requires clear responsibilities, valid data and a structured approach. Companies reporting for the first time in particular benefit from a methodical start. See also Creating a sustainability report - the most important basics.

1. preparation & requirements analysis

The first step is to clarify whether and from when the company is required to report. On this basis, the scope is defined, the relevant ESRS standards are identified and an initial gap analysis is carried out. You can find out more about the regulatory background in the overview of ESRS standards and current changes in the omnibus update.

2. conducting the materiality analysis

The double materiality analysis forms the core of the CSRD report. It determines which topics must be reported on - taking into account both external impacts and internal risks and opportunities. See also the importance of dual materiality in the CSRD and VSM & ESRS: How to make the switch later.

3. data collection & consolidation

All relevant ESG data must be collected, validated and prepared for the reporting structure - ideally in close cooperation with Controlling, HR, Purchasing, Production and Environmental Management. Use tools for ESG data management or Scope 3 transparency in real time.

4. report creation & integration

The report is created in accordance with the identified ESRS standards, prepared textually and graphically and integrated into the management report. It is delivered digitally in XBRL format (machine-readable). More on the technical side: EU taxonomy checklist and omnibus effects.

5. review & publication

The completed CSRD report must undergo an external audit (limited assurance). It is then published on the company website and, if necessary, on external portals. Find out more about audit processes and stumbling blocks in the third-party ESG audit guide.

Note: Many companies use specialized tools such as Multiplye for individual steps in order to automatically extract data from existing systems and speed up the reporting process.

Challenges & typical errors in CSRD reporting

Initial experience with CSRD clearly shows that many companies underestimate the effort and complexity of a complete CSRD report. Even the initial phase is characterized by methodological uncertainties, data gaps and delays. An analysis of the first published reports reveals where the biggest stumbling blocks lie - and how they can be avoided. Read more in the Omnibus article and Sustainability as a driver of growth.

Key findings from the first CSRD reports

• Double materiality: The analysis is the centerpiece - but is often not carried out systematically and rarely with the active involvement of external stakeholders.
• Integration into the strategy: Many companies recognize the potential of the materiality analysis, but still do not implement its results strategically enough. In-depth: ESG strategy for start-ups
• Value chain: Collecting meaningful data across the entire value chain remains a key problem. See Scope 3 emissions and supply chain
• Data quality and comparability: Most reports are still strongly narrative in nature; quantitative, standardized data is often lacking.
• Technology & verification: The requirements for XBRL, structured documentation and external verification (assurance) are often underestimated.
• Climate risk analysis: Climate risks are usually only addressed superficially, although they are central - often a point of criticism from auditors. Climate risk & financial planning

Typical mistakes & challenges at a glance

• Unclear reporting obligations: Many companies are unsure whether and from when they have to report - particularly due to the omnibus amendments and delayed national implementation. Result: delays or incomplete reports. Criticism of the EU omnibus package
• Weaknesses in the materiality analysis: Without a well-founded double materiality analysis, there is a risk of blind spots or too many irrelevant topics. Stakeholder involvement is often not systematic enough.
• Data chaos and poor quality: ESG data is scattered, often not standardized and difficult to understand. This makes validation more difficult and reduces the informative value of the reports. See API and data tools
• Lack of governance: There are often no clear responsibilities or resources for the CSRD process. There is room for improvement in coordination between departments.
• Climate risks & value chains: The risks of climate change are often only dealt with superficially. The requirements along the supply chain are uncharted territory for many companies.
• Underestimated technology: Implementation in XBRL format, digital publication and assurance checks are technically and organizationally more challenging than expected.
• Lack of comparability: The variety in length, structure and depth of the reports makes it difficult for external stakeholders to find their way around.

Conclusion: Many of these hurdles can be avoided: Those who plan early, rely on clear processes and governance and use external support in key phases can avoid the biggest mistakes from the first CSRD reports. A well-founded materiality analysis with external stakeholder involvement, structured data collection and preparation for technical and audit requirements are crucial.

Digitalization and CSRD reporting

Digitalization plays a central role in the efficient implementation of CSRD requirements. In future, sustainability information must be provided digitally and machine-readable in XBRL format (eXtensible Business Reporting Language). This facilitates automated evaluation by supervisory authorities, investors and other stakeholders. You can find out more about digitalization & tools in the LCA software article.

More and more companies are relying on specialized ESG software solutions to meet the increasing requirements. Such tools support the collection, consolidation, validation and preparation of the relevant data. They enable the integration of information from different areas of the company - such as controlling, HR, purchasing or production - and ensure consistent, traceable documentation. Overview of software solutions in the API & ESG tools guide.

The use of digital solutions is particularly recommended for companies that are reporting for the first time. They reduce manual effort, minimize sources of error and create the basis for sustainable and future-proof reporting. Digitalization also makes external auditing easier and speeds up the publication of the report.

Tip: Check at an early stage whether existing systems (such as ERP, environmental management or HR) can provide the required ESG data and evaluate which software solutions optimally support the CSRD process.

Benefits of a good CSRD report

A well-crafted CSRD report is much more than a mandatory regulatory document. It can be a strategic tool to build trust, convince investors and differentiate a company from the competition. See also Sustainability as a driver of growth.

• Strengthen trust among stakeholders: Transparent reports signal a sense of responsibility and future viability - to customers, employees, investors and the public.
• Facilitate access to sustainable financing: Banks and investors are increasingly focusing on ESG criteria - an audited report can facilitate access to capital.
• Meet supply chain requirements: Even without a formal reporting obligation, larger business partners often expect ESG transparency - a clearly structured CSRD report helps to meet these requirements.
• Improve internal processes: Structured data collection and governance discussions often lead to clearer responsibilities and better decisions within the company.
• Advantages in tenders: Many public and private tenders now require ESG data - a CSRD-compliant report can be crucial.

Investing early strengthens your position in the market - and at the same time reduces the risk of future sanctions or reputational damage. You can find more practical tips in the article on lifecycle assessments and in the overview of TNFD.

Johannes Fiegenbaum
Sustainability consultant for companies & start-ups
With over 10 years of experience in ESG and tech strategies, he supports companies in their entry into CSRD.
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