CSRD — Non Financial Reporting

The Corporate Sustainability Reporting Directive (CSRD) constitutes a revision of the current European Non-Financial Reporting Directive (NFRD) governing the disclosure of non-financial information. 

In France, the new provisions will replace the extra-financial performance statement (DPEF).

Entities already subject to the requirement to establish a DPEF will be subject to CSRD obligations from January 1, 2025 (based on 2024 data). For other entities, there will be a progressive implementation schedule.

The objective is to align the data production requirements for financial and non-financial reporting in an ecosystem where both dimensions will take on equal importance.

A reporting that will have to comply with a new normative framework

Main change:

Expansion of the scope of information to be disclosed

• Goals of aligning the business model and strategy with the objective of climate neutrality by 2050
• Qualitative and quantitative ambitions, and the trajectory
• Results/progression compared to ambitions
• Company’s value chains (and the identification of upstream and downstream relationships)
• Role of administrative, management, and governance bodies
• Most significant negative impacts
• Methodologies on information identification
• …

Introduction of double materiality (dual perspective)

The challenges must be assessed from a dual perspective:

• Impact materiality: the impact of the organization’s activities on people and the environment (‘inside out’)
• Financial materiality: the impact of the environment and external stakeholders on the organization’s performance (‘outside in’)

On these two axes, the challenges must be assessed with scoring models (that incorporate mandatory criteria).

Materiality must be assessed with stakeholders throughout the value chain.

A progressive implementation schedule

Here is a summary of the progressive implementation schedule:

• As of January 1^st, 2024 (initial publication during the calendar year 2025) for companies already reporting under NFRD.
• As of January 1^st, 2025 (initial publication during the calendar year 2026) for large companies not currently subject to NFRD and meeting at least two of three criteria (balance sheet €20M+ / revenue €40M+ / more than 250 employees).
• As of January 1^st, 2026 (initial publication during the calendar year 2027) for SMEs meeting at least two criteria (balance sheet €4M+ / revenue €8M+ / more than 50 employees). SMEs will be subject to a limited set of standards than the general set of CSRD standards.
• As of January 1^st, 2027 (initial publication during the calendar year 2029) for non-European companies meeting specific criteria (company listed on EU regulated markets + annual net turnover in EU territory of €150M+ + subsidiary in the EU).