The Corporate Sustainability Reporting Directive (CSRD) is reshaping how companies disclose sustainability information, requiring more transparency and accountability in environmental, social, and governance (ESG) matters. This regulation builds on the existing Non-Financial Reporting Directive (NFRD) and expands reporting obligations to a broader range of companies.
For consultants, keeping up with the CSRD timeline is essential to ensure your clients are compliant, avoid penalties, and streamline their ESG reporting processes. This guide breaks down the key reporting deadlines and what companies need to do at each stage.
Who needs to comply with the CSRD?
Unlike previously voluntary reporting standards like the TCFD, the CSRD is a mandatory reporting requirement that applies to a broad range of companies both within and outside the European Union (EU). Compliance is determined by specific criteria related to company size, revenue, and business operations within the EU.
The CSRD applies to:
- Large EU companies meeting at least two of the following conditions:
- More than 250 employees
- Net turnover exceeding €40 million
- Total assets exceeding €20 million
- Non-EU companies generating at least €150 million in net turnover within the EU and having at least one EU subsidiary or branch
- Listed small and medium-sized enterprises (SMEs) with certain exemptions
By expanding its scope, the CSRD ensures greater accountability from companies with significant EU business activities, even if they are headquartered elsewhere.
Key deadlines in the CSRD timeline
January 1, 2024 – Reporting starts for large public interest entities
- Applies to companies already subject to the NFRD
- These companies must submit their first CSRD-compliant sustainability reports in 2025 based on 2024 data
- This phase primarily affects large listed companies, banks, and insurance firms
January 1, 2025 – Reporting starts for other large companies
- Expands compliance requirements to all large undertakings, even those not previously covered by the NFRD
- Companies must meet at least two of the three size thresholds (employees, turnover, assets)
- First reports under this phase are due in 2026 based on 2025 data
January 1, 2026 – Reporting starts for listed SMEs
- Listed SMEs must comply, but they can opt for a two-year deferral, pushing their first reporting deadline to 2028
- Those who choose to report in 2026 will need to submit disclosures by 2027
January 1, 2028 – Reporting starts for non-EU companies
- Applies to non-EU parent companies with €150 million+ turnover in the EU
- Must report on EU-based operations, ensuring global corporate accountability
- First reports due in 2029 based on 2028 data
| Date | Reporting Requirement | Key Details | First Reports Due |
| January 1, 2024 | Reporting starts for large public interest entities | Applies to companies already subject to the Non-Financial Reporting Directive (NFRD)- Affects large listed companies, banks, and insurance firms | 2025 |
| January 1, 2025 | Reporting starts for other large companies | Expands compliance to all large undertakings, even those not previously covered by the NFRD- Companies must meet at least two of the three size thresholds (employees, turnover, assets) | 2026 |
| January 1, 2026 | Reporting starts for listed SMEs | Listed SMEs must comply but can opt for a two-year deferral, delaying their first report to 2028- Those reporting in 2026 must submit disclosures by 2027 | 2027 or 2028 |
| January 1, 2028 | Reporting starts for non-EU companies | Applies to non-EU parent companies with €150 million+ turnover in the EU– Must report on EU-based operations for global corporate accountability | 2029 |
Given the choice, why would SMEs choose to report earlier?
Some SMEs may choose to comply with CSRD reporting requirements before the 2028 deadline to align with investors’ growing demand for ESG transparency. Many institutional investors consider sustainability performance when allocating capital, and early compliance can position SMEs as leaders in responsible business practices. Additionally, proactively integrating CSRD disclosures can help SMEs build stronger relationships with stakeholders, including banks, insurers, and larger corporate clients who require ESG-aligned supply chains.
Despite the benefits, many SMEs face significant hurdles in preparing for CSRD compliance. Unlike larger corporations with dedicated sustainability teams, SMEs often lack the internal resources to manage complex ESG reporting requirements. This is why many end up turning to consultants, but the high price tags of many consulting firms may turn clients away. Some consultants will recognize this and start leveraging AI-powered ESG tools like Manifest Climate in order to speed up their workflows and bring down internal costs.
Preparing for CSRD compliance: steps consultants should take for clients
Ensuring clients are ready for CSRD compliance involves proactive planning and structured processes. We recommend consultants adopt the following sequence when working with clients on CSRD compliance.
1. Assess your clients’ eligibility
Before diving into reporting requirements, consultants should evaluate whether their client falls within CSRD’s scope. Begin by reviewing company size and financials, examining the number of employees, annual turnover, and balance sheet totals. If a company meets at least two of the three CSRD size thresholds, compliance is mandatory. For non-EU companies, checking their EU operations is crucial. If they generate significant revenue within the EU, they may be required to report. Lastly, determining applicable deadlines ensures businesses prepare well in advance of their reporting obligations.
2. Conduct a materiality assessment
A materiality assessment helps businesses identify the ESG factors most relevant to their operations. Consultants should start by engaging leadership and key stakeholders through structured interviews and workshops to understand business priorities. Conducting a double materiality assessment—analyzing both financial materiality (how sustainability issues impact the company) and impact materiality (how the company affects the environment and society)—ensures comprehensive ESG disclosure. Reviewing existing ESG policies, sustainability initiatives, and past disclosures will highlight gaps in reporting. The findings should be documented clearly, forming the foundation of an ESG reporting strategy aligned with CSRD requirements.
3. Strengthen data collection and reporting processes
Data collection is at the heart of CSRD compliance. Consultants must first identify the key data points that need to be tracked and ensure these metrics meet CSRD disclosure expectations. Work with your clients to centralize data collection by implementing digital tools that automate gathering information from multiple departments, reducing reliance on manual spreadsheets. Data accuracy is crucial, so establishing validation protocols like internal reviews and audits will ensure completeness and reliability. Aligning data with CSRD disclosure templates allows for a streamlined reporting process, making compliance easier and more efficient.
4. Invest in expert technology
Given the complexity of CSRD compliance, leveraging AI-driven compliance tools significantly reduces manual effort and improves accuracy. Internally, we recommend that consultants leverage an AI-powered review tool like Manifest Climate, which automates CSRD gap analysis, speeding up manual reviews by at least 10X. Real-time regulatory monitoring ensures that companies stay updated on evolving CSRD requirements, avoiding last-minute compliance challenges. Additionally, choosing a tool that provides traceability (linking ESG data back to original sources) improves confidence in audit readiness and transparency.
Prepare for CSRD compliance effectively with Manifest Climate
Meeting CSRD deadlines doesn’t have to be overwhelming. With the right tools and guidance, businesses can streamline reporting and ensure compliance. Manifest Climate helps consultants and companies navigate CSRD obligations efficiently with AI-powered insights, gap assessments, and automated reporting features.Ready to simplify CSRD compliance? Book a demo today and get ahead of the reporting deadlines.
