Preparing for the CSRD's Impact on US Companies
Learn how the CSRD will impact US companies.
Big changes are coming to corporate sustainability reporting in the EU and soon in the rest of the world. Starting in fiscal year 2024, the first wave of in-scope companies will be required to disclose ESG impacts under the EU’s Corporate Sustainability Reporting Directive (CSRD). The CSRD overhauls the 2014 Non-Financial Reporting Directive (NFRD), the EU’s current sustainability framework, and aims to improve the quality of data for investors while helping the EU meet its policy goals under the European Green Deal.
In addition to requiring more robust reporting on environmental and human rights impacts and sustainability-related risks, the CSRD drastically increases the number of in-scope companies from around 12,000 to over 50,000.
And that’s not just EU companies. Like many recent rulings coming out of the EU, the CSRD is designed to drive the rest of the global economy towards meaningful action and ESG disclosure. Over 10,000 non-EU companies, including around 3,000 US companies, will be subject to the CSRD in the coming years.
Read on to learn how the CSRD will impact US companies, what they’ll need to disclose, and what steps they should take to prepare.
Wondering what other ESG reporting frameworks and regulations to keep an eye on? Check out our in-depth guide.
Who's Impacted by the CSRD?
The CSRD impacts three groups of companies – large companies based in the EU, small and medium enterprises (SMEs) in the EU, and certain non-EU parent companies doing business in the EU.
Large EU Companies
Satisfies at least two of the following:
• Over 250 employees
• Over €40M turnover
• Over €20M balance sheet assets
EU SMEs
• Less than 250 employees
• Less than €40M turnover
• Less than €20M total assets
Non-EU Companies
• €150M net turnover in the EU
• One branch or subsidiary in the EU
Key Features and Requirements
CROSS-CUTTING DISCLOSURES
Two cross-cutting standards cover overarching reporting requirements on governance, strategy, impacts, risks and opportunities, and metrics and targets. These are tightly aligned with the TCFD’s recommendations. Disclosure requirements include:
- Material ESG risks, opportunities, and impacts (operational and across the value chain)
- Impact of risks and opportunities on business model
- Sustainability due diligence processes
- Risk management processes, board oversight, integration of sustainability KPIs into incentivization schemes
- Policies to manage material ESG impacts
- Sustainability targets, goals, and metrics
- Action plans for addressing material ESG topics
DOUBLE MATERIALITY
The CSRD is the first major legislation mandating a double materiality approach to all sustainability topics in the European Sustainability Reporting Standards (ESRS). This means you’ll need to consider how each sustainability issue financially impacts your business and how your business positively or negatively impacts that issue.
REPORTING ACROSS A BROAD RANGE OF TOPICS
On top of the mandatory cross-cutting disclosures listed above, the CSRD requires disclosures on material impacts, risks, and opportunities across various ESG topics. While these issues are technically subject to double materiality, it’s highly unlikely that you’ll be able to omit more than a few (if any). For instance, topics like Climate Change, Biodiversity, Own Workforce, Workes in the Value Chain, and Affected Communities apply to almost all businesses.
Reporting requirements for each topic are defined in each of the twelve ESRSs.
*Note: If Climate Change is material to your business (spoiler alert, it is), you’ll need to disclose your full GHG impact, including Scope 3 emissions.
ASSURANCE
All disclosures are subject to assurance, with limited assurance required in FY26 and reasonable assurance required in FY28.
Decoding the Jargon: CSRD & the ESRS
If you’re familiar with the CSRD, you may have heard of the European Sustainability Reporting Standards (ESRS). The 12 standards lay out the reporting requirements of the CSRD, covering topics like Climate Change, Biodiversity, Own Workforce, Value Chain Workers, and more.
The European Commission recently proposed some changes to the ESRS, allowing companies with less than 700 employees to omit Scope 3 and Own Workforce disclosures during the first year. Another key change is that, except for ESRS 2 (General Disclosures), all standards are subject to double materiality assessments. In other words, you only need to report on topics you deem material to your business. Read about the other changes here.
Don’t Forget About the EU Taxonomy
Is your business in scope under the CSRD? That means you’ll also have to disclose your company’s percentage of turnover, revenue, and capital expenditures aligned with the six EU taxonomy objectives.
ESRS Standards: A Closer Look
Cross-Cutting Standards
ESRS 1: General Requirements
ESRS 2: General Disclosures*
Environmental Standards
ESRS 1: Climate Change
ESRS 2: Pollution
ESRS 3: Water & Marine Resources
ESRS 4: Biodiversity & Ecosystems
ESRS 5: Resource Use & Circular Economy
Social Standards
ESRS 1: Own Workforce
ESRS 2: Workers in the Value Chain
ESRS 3: Affected Communities
ESRS 4: Consumers & End-Users
Governance Standards
ESRS 1: Business Conduct
Steps to Prepare
Non-EU companies subject to the CSRD will submit their first disclosures in 2029 for the FY 2028 reporting year. That may seem far away, but many of the steps you’ll need to take to comply with the standards require years of planning and implementation.
Create a Cross-Functional Working Group: To gather the information needed for CSRD compliance, ESG needs to be integrated into your standard business functions – at a minimum risk, legal, procurement, and finance. You simply won't be able to make it happen as a siloed ESG department. This is especially true when it comes to nuanced ESRS topics like Biodiversity, Circularity, and Value Chain Workers.
Companies that’ll fall flat-footed on the CSRD will be those that aren’t integrating their ESG efforts across all departments. The expectations of the CSRD extend far past what your ESG or even DEI+J team can accomplish alone.
Conduct a Double Materiality Assessment: Double materiality is a defining feature of compliant CSRD reporting. Using the 12 ESRSs as a guide, conduct a double materiality assessment to determine which ESG topics impact your business and how your business impacts those issues.
*Note: Even though the ESRSs are subject to double materiality, don’t just write off the hard topics—Biodiversity, Value Chain Workers, Affected Communities, and others. These issues impact nearly all companies. Just because it might be more challenging to gather data on these topics (compared to, say, Climate Change, which has a very quantifiable, agreed-upon set of KPIs), that doesn’t mean you can ignore them.
Create a Climate Transition Plan: As part of your Climate Change disclosure, you’ll need to create a 1.5C°-aligned climate transition plan. How will you reduce your biggest Scope 1 and 2 emissions sources (including fuel and energy use)? Does your business model (or part of it) need to change to support a net zero economy? Developing a plan means engaging business leaders from your cross-departmental working group and getting tactical about the possibilities – it'll be an all-hands-on-deck effort!
Build a Strategy for Scope 3 Emissions: Although it remains to be seen whether the SEC will mandate Scope 3 reporting, the CSRD is crystal clear. Scope 3 disclosure is required for all in-scope companies. Establishing effective reporting processes with your suppliers can take years, let alone implementing a Scope 3 reduction plan. Don’t put this step off – remember that by FY 2028, your 2030 GHG emissions goals will only be 1-2 years away.
If you don’t have a Scope 3 strategy, your first task will be opening lines of communication with your suppliers, all the way down to the source. Be sure to clearly communicate expectations and data reporting requirements. We strongly recommend using a supplier management platform like CDP Supply Chain or EcoVadis to collect data, engage your suppliers, and monitor progress.
Educate Your Board on Sustainability: Part of your General Disclosures include Board oversight of sustainability issues and their involvement in managing risks and opportunities. For many companies, education is the first step. Consider screening new Board members for competence on ESG topics and work towards adopting a governance structure that meaningfully incorporates Board and Executive oversight.
Engage an Assurance Provider: As a US company, your disclosures will be subject to reasonable assurance right off the bat. If you don’t have an assurance provider, engage one now to get their advice upfront. Ensure you understand the expectations so you can develop your programs and disclosures with these in mind. At a minimum, you'll need a clear audit trail and documentation of processes and controls to support your disclosures.
As with many recent ESG policies in the EU, the CSRD has far-reaching implications. Even if you’re not officially in-scope under the CSRD, it pays to stay ahead of the curve. Frameworks and regulations coming out of the EU have always been indicative of where the world is headed on ESG and corporate accountability.
Regulation aside, investor expectations will only continue to rise. Your ability to produce auditable ESG reports with investor-ready information is crucial, regardless of whether you’re also required to do so by law.
Need help conducting a double materiality assessment or developing an integrated ESG strategy to support your CSRD disclosures? Our team has helped countless brands implement ESG reporting strategies that comply with emerging regulations while building business resilience.
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