A PDF version of the full publication is attached here: Take the next step - decide how to report under CSRD (PDF 940kb)

Assessing whether a company is in scope of the European Union (EU) Corporate Sustainability Reporting Directive (CSRD) has some inherent complexities. There are, for example, several ways in which a company can be scoped into the EU’s new mandatory sustainability reporting requirements. The scope of companies directly impacted is also expansive — including US and other non-EU headquartered companies — making scoping a question that merits priority focus by companies with operations in the EU.

For all of its prescriptive requirements, however, the CSRD provides exemptions that allow for some discretion for non-EU headquartered companies in determining which entities in the organization need to prepare their own reporting. As a result, a company may have options in its approach to fulfilling its CSRD reporting requirements. Deciding which approach is best will be driven by multiple company-specific factors, including its specific reporting requirements and the needs of its stakeholders.

Management of any non-EU headquartered company considering reporting options must grapple with one crucial question: does individual subsidiary or global group reporting (or something in between) best balance the company’s sustainability communication strategy with effective and efficient compliance with the reporting requirements. The answer will depend on a company’s individual facts and circumstances and may have a dramatic impact on the nature and extent of resources needed to prepare for reporting.

Companies will benefit from taking a methodical approach to this assessment, contemplating the qualitative and quantitative factors that influence the benefits and burdens of complying under different scenarios. And because this reporting decision will dictate how a company assesses materiality and drives the design of new systems, processes, and controls, it is a critical step to take now.

This In the loop is designed to provide practical considerations that may inform a company’s determination of the most effective reporting approach for its organization under the CSRD. Each company’s assessment will nevertheless be influenced by its own facts and circumstances, some of which may not be addressed in this document.