The EU Corporate Sustainability Reporting Directive

image of hands in a meeting with charts

By Guillaume Février and Christian Stotz

This article has been published in the September issue of the HKA, by bved: Die HKA – bved 

The Corporate Sustainability Reporting Directive (CSRD) came into force in 2023. It is a European legislation designed to standardise and broaden the corporate sustainability reporting, which is outlined by its predecessor, the Non-Financial Reporting Directive (NFRD).  

As part of the EU Green Deal, which aims to reach the carbon footprint net-zero by 2050, capital flows are to be increasingly directed towards sustainable economic activities in the future. To this end, the so-called “greenwashing” has to be avoided in a preventive manner. Greenwashing describes a misleading form of corporate Environmental, Social and Governance (ESG) communication that is intended to build a particularly environmentally friendly and responsible image without creating a real basis of reliable sustainable information, hindering investors from making informed investment decisions. The use of this practice has exposed significant limitations in the quality and quantity of sustainability information provided by companies. To address the issue, the CSRD is part of the EU’s “action plan on financing sustainable growth”, which has three overarching objectives:  

  1. Redirecting capital flows to sustainable investments in order to achieve sustainable and inclusive growth; 
  2. Addressing the financial risks arising from climate change, natural disasters, environmental degradation and social issues; 
  3. Promoting transparency and a focus on long-term impacts in financial and economic activity. 

Scope of the CSRD: Which companies are affected and when? 

The CSRD is intended to significantly increase the amount of sustainability information available on the EU economy. It therefore expands the scope of the NFRD, increasing the number of companies subject to ESG reporting obligations from around 11,000 to approximately 50,000 entities. Until now, the NFRD only mandated reporting for large companies that are of public interest. It also includes non-EU companies listed on the EU-regulated market. The CSRD extends these reporting obligations to all large companies. 

According to Article 3 of the amended Accounting Directive, companies are defined as large companies if they meet two of the following three criteria: 

  • An average of more than 250 employees during the financial year 
  • Balance sheet total of more than 25 million euros 
  • Net annual turnover of more than 50 million euros 

As of January 1, 2024, the companies that were already subject to the NFRD fell within the scope of the CSRD. For the 2025 financial year, the CSRD will then affect all other large companies that meet two of the three criteria mentioned above but have not yet had to report on their sustainability under the NFRD. 

The directive will then extend its reporting obligations in 2027 (for the 2026 financial year) to all listed small and medium-sized enterprises (SMEs) that meet two of the following criteria: 

  • An average of 10 to 250 employees during the financial year 
  • Balance sheet total from 350,000 to 20 million euros 
  • Net annual turnover from 700,000 to 40 million euros 

However, SMEs will have the option to opt out of the reporting obligation until 2028. 

It should be noted that micro-enterprises that do not exceed a balance sheet total of more than 450,000 euros, a net turnover of 900,000 euros or an average of 10 employees in the financial year are exempt from the requirements of the directive.  

Furthermore, from January 1, 2029 (for the 2028 financial year), the CSRD will also apply to non-European companies with branches or subsidiaries in the EU, should they reach or exceed a net turnover of 150 million euros within the Union. 

What type of information needs to be provided? 

The CSRD mandates companies to include a broader range of information in their sustainability reports than under the NFRD. It comprises a list of environmental impacts, such as greenhouse gas emissions, pollution prevention strategy and energy consumption, as well as social and employee matters, encompassing diversity, human rights, and labour practices. In addition, companies must report on anti-corruption, bribery measures and the governance structures they have established internally to manage these risks.  

A major challenge of the CSRD is to ensure that the disclosed sustainability information is relevant, high-quality, and trustworthy. To achieve this, the Directive prescribes a double materiality assessment. In practice, it requires companies to assess sustainability aspects from two perspectives: how their activities impact people and the environment, and how sustainability-related trends create risks or opportunities for their business. Under this concept, a sustainability aspect can be material from either an impact perspective or a risk and opportunity perspective. This assessment is important to guarantee the CSRD compliance, as it determines what is essential for inclusion in the sustainability report, what can be omitted. 

To ensure the accuracy of the sustainability reporting, the CSRD mandates third-party review. For the latter, companies must only to obtain limited assurance, a less rigorous level of scrutiny compared to a financial audit. Under limited assurance, the auditors simply determine that there is no indication of material misstatements in the information provided. While a stricter level of assurance is not currently mandatory, the European Commission may reassess this requirement after 2028. 

EVVE welcomes new Managing Director

WE Data opening ceremony with Sofia Lettenbichler and Markus Weidling

Brussels 03/09/2024 – The European Association for the Consumption-based Billing of Energy Costs (EVVE) is pleased to announce the appointment of Sofia Lettenbichler as its new Managing Director. Sofia succeeds Udo Wasser, who has been a cornerstone of EVVE for more than 15 years, significantly contributing to the association’s growth and influence within the European energy sector.

A proven leader in energy and sustainability

Sofia Lettenbichler brings a wealth of experience in energy policy and European affairs to EVVE. Throughout her career, she has held key leadership roles focused on energy, digitalisation and sustainability policy, driving initiatives that promote the energy transition, with a special focus on heat.

In her new role at EVVE, Sofia will lead the association’s efforts to advocate for transparent and equitable energy billing systems across Europe. Her deep expertise will be crucial as EVVE navigates the challenges posed by the rapidly evolving energy landscape, particularly in the context of the European Union’s sustainability goals.

A new chapter for EVVE

Reflecting on her appointment, Sofia Lettenbichler commented, “I am honored to join EVVE at such pivotal time for the energy sector and the EU. As the EU intensifies its efforts towards delivering the energy transition and raises the ambitions for energy efficiency, I am eager to collaborate with our members to further EVVE’s mission and enhancing energy efficiency and sustainability in the built environment.”

Udo Wasser, who has been with EVVE for more than 15 years, shared his confidence in the future under Sofia’s leadership: “With Sofia’s track record in European matters, EVVE will be decisively strengthened to master the challenges of the future.”

Markus Weidling, CEO of EVVE, also expressed his enthusiasm, stating, “I am delighted to welcome Sofia to the team. Her dedication to energy and water efficiency will be a tremendous asset as we continue to drive EVVE’s agenda on battling climate change.”

Reflecting on EUSEW 2024

EUSEW 2024 event presentation

This week (11/06/2024), EVVE attended the EU Sustainable Energy Week 2024 in Brussels. From June 11th to June 13th, we joined experts, policymakers, NGOs, and industry leaders to discuss Europe’s energy future.

This year’s EUSEW highlighted the importance of implementing the Fit for 55 package in decarbonising the economy and achieving the EU climate targets. The main take away is an harmonious implementation of what has been achieved during the previous mandate, emphasising consumer engagement and a socially just transition.

Power system flexibility emerged as a significant opportunity for enhancing energy efficiency. By empowering consumers with the right tools, we can foster positive behavioural changes, help them optimise their energy use and ultimately increase the energy available while reducing their energy bills down.

However, awareness and education are crucial in harnessing the benefits of new technologies. Ensuring users understand and use devices effectively will be essential in fostering long-term sustainable energy practices.

The discussions underscored the importance of social justice in the energy transition. Protecting vulnerable households and ensuring equitable access to benefits are essential priorities, as no one should be left behind.

Looking ahead, as reaffirmed by Vice-President Maroš Šefčovič, the EU’s commitment to the Green Deal and achieving Net-Zero emissions by 2050 remains strong, despite various challenges.

With the right technologies, incentives, and a robust regulatory framework, a sustainable future is within our grasp.

E.V.V.E. elects new Executive Committee

Ocea Smart Building joins WE Data Europe: expanding the network for smart metering and resource management.

Nicolai Kuß is the new president of the E.V.V.E. Chief Sales Officer (CSO) at Techem GmbH, Kuß was unanimously elected to the post at the E.V.V.E. general meeting. He succeeds Thomas Zinnöcker, who successfully led the association over three terms in office.

Prof. Christoph Schmucker, managing partner at BRUNATA-METRONA GmbH & Co. KG, was unanimously elected to the office of vice-president.

Mr. Oliver Geer (BRUNATA-METRONA GmbH, Germany,), Dr. Helmut Gradischnik (Messtechnik Ges.m.b.H. & CoKG, Austria), Dr. Hagen Lessing (ista SE, Germany,) and Ralf Moysig (Brunata A/S, Denmark) were re-elected as executive committee members.

Commenting on his election, Nicolai Kuß said, “I would like to thank the E.V.V.E. management team, Mr. Christian Sperber and Mr. Udo Wasser, for their successful work and the members for the trust they have placed in me. I look forward to working together to modernise the association and to overcome the challenges we face. Key milestones along this road are, in my view, establishing an office in Brussels to give us a presence there and modernisation of the association’s digital presence.”

“Together the E.V.V.E. can continue to achieve a great deal in the future,” added Prof. Christoph Schmucker. “By creating transparency with respect to heating energy consumption, member businesses make an important contribution to saving energy. Together we can reduce carbon emissions in Europe and mitigate the consequences of the current energy crisis. Just one more reason the association is a valued partner on numerous Brussels committees.”

E.V.V.E. press release

image of windmills and countryside

“Energy efficiency is a key driver of the energy transition in buildings. But if legislation from Brussels doesn’t filter down to the various capitals, that of course brings little benefit to the climate or consumers,” explains Christian Sperber, executive director of E.V.V.E. This impression was confirmed at a one-day congress in Brussels on November 6 held to celebrate the E.V.V.E.’s 25th anniversary. Niels Ladefoged, team leader at the European Commission, pointed to the early days of the SAVE programme in the 1990s, and set out the European Commission’s ambitions, formulated in the Clean Energy Package. The afternoon saw Dr. Robert Gorzycki, President of RSM URSUS, giving a presentation on how providing usage information affects heating energy consumption and how better use could be made of this. E.V.V.E. President Thomas Zinnöcker praised the measures being taken by EU legislators. In his view, the last 20 years have seen the creation of a sensible framework for promoting energy efficiency measures and a clear recognition of the critical importance of consumers. Zinnöcker nonetheless sees room for improvement in terms of implementation by member states, “The fact that, even years after the European legislation entered into force, some countries have still not transposed it into national law sends a bad signal to consumers and business. It erodes the perception of reliability and predictability. The biggest loser, however, is the climate.” Zinnöcker would therefore like to see the European Commission doing more to ensure that the EED is implemented rapidly and in full.