How CSRD Works – 6 Questions and Answers About the New Sustainability Directive

From carbon emissions to equality and working conditions – CSRD tightens the requirements for how companies report their impact on people and the environment. But what does the new sustainability directive mean in practice? Which companies are affected? And what role does HR play in all of this? Here are your answers!

Green, climate-smart, and circular. Ethical supply chains and fair working conditions. Sustainability has never been talked about as much as it is now. Do you, like many others, find it tricky to navigate through a jungle of abbreviations and concepts? Wondering what your company will need to report, and when? In this article, we'll do our best to straighten out your question marks around sustainability reporting, focusing on the new CSRD directive.

What is CSRD?

First things first: what does CSRD mean? CSRD stands for the Corporate Sustainability Reporting Directive and entails stricter requirements on how companies report their environmental and social impact. The directive replaces the previous framework for sustainability reporting in place since 2014 and is part of the so-called European Green Deal, aiming for the EU to be climate-neutral by 2050.

On May 29, 2024, the Swedish Parliament passed new rules on sustainability reporting (in Swedish) implementing CSRD into Swedish law, effective from July 1, 2024.

Wat is the purpose of the new rules?

Comparing apples to oranges. That's a way to describe the problem with the current state of sustainability reporting, something the EU now intends to address. Until now, there's been a lack of a standardized template for what a sustainability report should contain, allowing companies to essentially choose what to include (or not include).

With CSRD, however, the idea is that all companies will measure and present the same key figures in a more uniform way (even if requirements will differ slightly between sectors). By separating apples from oranges, it becomes easier for investors, customers, and the public to compare how different companies perform when it comes to sustainability.

Do all companies need to report according to CSRD?

No, the requirements do not apply to all companies – but significantly more than before. Unlike the previous NFRD framework, which primarily covered the largest companies, CSRD also includes more medium-sized companies based on size and turnover.

However, in the spring of 2025, the EU Commission proposed an Omnibus package aimed at reducing the administrative burden on companies. If approved, this proposal will bring several changes to which companies are covered by CSRD:

• Companies with fewer than 1,000 employees are completely exempt from the CSRD reporting requirement. This means that many medium-sized companies previously included will now receive an exemption.
• Reporting for certain companies is postponed. Large companies that would have started reporting in 2026 can now wait until 2028. Small and medium-sized publicly listed companies can delay their reporting until 2029.
• A voluntary reporting standard for smaller companies (VSME) is proposed for those who still wish to demonstrate transparency in their sustainability efforts.

What needs to be reported?

• Environment: This includes climate change, pollution, water and marine resources, and biodiversity.
  
  
• Social Responsibility: This encompasses equality, diversity, human rights, equity, and working conditions throughout the company's operations.
  
  
• Corporate Governance: Questions regarding, for instance, the role and composition of the board, efforts against corruption and bribery, compliance with regulations, and due diligence – the process of evaluating a company during a merger or acquisition.

What are the major changes in CSRD?

It is clear that stricter rules for corporate sustainability efforts are on the horizon, but what exactly is new in the CSRD? Here are the key points to be aware of:

• Covers more companies – but not all. Initially, the idea was that CSRD would apply to thousands more companies than before. However, according to the EU's new Omnibus proposal, the threshold will be raised: only companies with over 1,000 employees need to fully comply with the directive. Smaller companies can thus breathe a sigh of relief – at least for now.
  
  
• Clear rules – the same standard for everyone. One of the major updates in CSRD is the introduction of the European Sustainability Reporting Standards (ESRS) – a kind of template for what sustainability reporting should include. This eliminates the guesswork for companies, though it has also raised concerns about complexity. Therefore, the Omnibus proposal suggests simplifying the standards and reducing the number of data points.
  
  
• Double materiality analysis – viewing sustainability from two angles. In the future, companies must analyze their sustainability impact from two different perspectives: how the company's operations affect people and the planet, and how changes in the planet (such as climate change) affect the company.
  
  
• Stricter auditing. The company's sustainability report must be reviewed by an auditor or another external examiner to ensure good quality control.
  
  
• Annual report + sustainability reporting = true. To further increase transparency, the sustainability report will now be an integrated part of the annual report. Additionally, it must be provided in a digital format.

What does this mean for HR?

So, how does HR fit into the picture, you might wonder? Well, as we've previously mentioned, CSRD imposes new requirements on companies to report not only on environmental and climate issues but also on how they manage human resources.

For HR, this means a greater responsibility to collect and report key metrics related to:

• Diversity and inclusion, such as gender distribution, age structure, and representation of various groups
• Gender pay differences
• Working conditions, including employment types, salary levels, and workplace risks.
• Employee satisfaction, based on engagement surveys and well-being assessments
• Absenteeism, covering both short-term and long-term sick leave
• Employee turnover, both voluntary and involuntary
• Parental leave and family-related leave
• Skill development, such as training initiatives and career advancement opportunities

With this in mind, it will be more important than ever for employers to establish effective routines and tools to collect data and compile key metrics related to personnel.

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Lost in the sustainability lingo? Here's a small glossary to help you.

ESG (Environmental, Social and Governance)
A set of guidelines divided into the main areas of environment, social responsibility, and corporate governance. Not legislation, but rather an umbrella term for corporate sustainability efforts.

CSRD (Corporate Sustainability Reporting Directive)
A new EU directive that requires companies to report their sustainability work in a more standardized way. Its purpose is to increase the transparency and comparability of corporate sustainability reporting.

ESRS (Environmental, Social, and Governance Reporting Standards) 
A new common standard related to CSRD with detailed rules for how sustainability reporting should be conducted.

Double Materiality Assessment
A method to determine which sustainability issues are most pertinent to a company. It considers both how the company impacts the external environment (such as the environment and society) and how sustainability factors affect the company's economy and business model. This is a key component of CSRD and dictates which sustainability aspects the company must report.

Omnibus package (2025)
An EU proposal that, among other things, raises the threshold for CSRD reporting to 1,000 employees, postpones timelines, and suggests simplifications in the ESRS reporting standard.