Large corporation under CSRD — all sectors
Produce an auditable reporting, not an ESG narrative

The CSRD directive (2022/2464/EU) covers all large companies, not just real-estate or financial actors. B2B services, distribution, healthcare, transport, energy, tech, consulting, large retail, chemicals, agri-food, large farming operations: you are probably subject to the CSRD (NFRD wave 1, large-company wave 2, or post-Omnibus 2026 according to thresholds). The stake is not formal compliance: it is the production of quantified, traceable, auditable datapoints — which hold against the auditor's limited assurance and analysts' ESG questionnaires. NORMAXIS structures this production, sector by sector, backing it with independent third-party proprietary tools matched to the real materiality of your activity.

Frame your CSRD reporting See CSRD pillar

Who is in scope

Non-real-estate, non-financial large companies: CSRD also applies.

Real-estate / industrial / investor verticals cover part of the CSRD audience, but not all. Here are the additional profiles for which NORMAXIS builds the engagement.

B2B services & consulting

Consultancies, software vendors, agencies, IT services, business-to-business providers. Main materiality: E1 (travel, data centres), S1 (employees), G1 (business conduct).

Distribution & retail

Food retail, specialised retail, e-commerce. Materiality: E1 (Scope 3 upstream supply chain), E5 (packaging, waste), S2 (value-chain workers), E4 (if land or agricultural supply chain).

Healthcare & pharma

Laboratories, clinics, private hospital groups, biotech. Materiality: S4 (consumers and end-users), S1 (working conditions), E2 (chemical effluents), G1 (R&D ethics, clinical trials).

Transport & mobility

Road carriers, rail, airlines, maritime, urban mobility operators. Materiality: E1 (dominant Scopes 1-2-3), E2 (local pollution), S1, E4 (land footprint).

Energy & utilities

Electricity producers, gas providers, water and waste operators, urban heating. Materiality: E1 (carbon intensity), E3 (water, marine), E4 (land footprint), S3 (neighbouring communities).

Tech & digital

Software vendors, platforms, hosters, telecom operators. Materiality: E1 (data centres, Scope 3 equipment), E5 (electronic waste), S1, G1 (AI ethics, cybersecurity).

Orientation

Does your activity match a dedicated profile?

Before reading on, check if your main activity matches one of the dedicated profiles — you will find a more targeted engagement there.

Listed REIT

If your main activity is owning / managing listed real-estate portfolios, see the dedicated page: one diagnostic, four frameworks served (CSRD E4 · SFDR PAI 7 · Taxonomy · French art. 29 LEC).

See listed REIT page →

ESG investor

If you are an asset-management company, insurer, fund, bank: SFDR (articles 8/9, PAIs), Taxonomy (DNSH criterion 6), French article 29 LEC, TNFD compliance. Portfolio diagnostic.

See ESG investor page →

Neither matches? You are in the right place — the page continues below.

Our engagement

Five levels for an auditable CSRD reporting, sector by sector.

NORMAXIS adapts the engagement to your sector and ESG maturity. Proprietary tools operated by IRICE as an independent third party under ISO/IEC 17065 — BPS (biodiversity) and Efficarbone (construction-site carbon) — are activated when materiality justifies. For engineering and field measurements, ARKEMEP and ARKENOR intervene when needed.

Level 1

Sector-specific double materiality assessment

Five-step method (value-chain mapping, long list, stakeholder consultation, scoring, governance validation) tailored to your sector. Identification of IROs and material ESRS with documented justification. Standalone materiality report opposable to the auditor.

Level 2

Multi-ESRS gap analysis

Stocktaking of available data versus material thematic ESRS requirements. Identification of data to collect, tools to implement, competences to mobilise. Costed roadmap by ESRS, prioritisation year 1 / year 2 / year 3.

Level 3

Datapoint production

ESRS E1 climate: GHG scope 1-2-3 inventory (GHG Protocol), 1.5°C transition plan, CBAM articulation if relevant. ESRS E4 biodiversity (if material): BPS diagnostic of sites / upstream chain, IRICE attestation as independent third party. ESRS E5 circularity, S1-S4 social, G1 governance: proven methods, traceable datapoints.

Level 4

Transition plans

Climate transition plan aligned with 1.5°C (required by ESRS E1 and presumptively material for all large companies). Biodiversity transition plan aligned with Kunming-Montréal and the French national biodiversity strategy to 2030 when E4 is material. Quantified targets, 2030/2050 trajectory, budget, governance.

Level 5

Sustainability-audit preparation

Building the audit trail: documented method, archived source data, third-party attestations, consultation evidence. Structured dialogue with the statutory auditor or the independent third-party body in limited assurance. Preparation for reasonable assurance (shift by 2028).

Calendar alert

Omnibus 2026 redefines your scope.

The Omnibus directive (European Commission proposal February 2025, "stop-the-clock" track adopted by EU Directive 2025/794 of 3 April 2025) substantially modifies the CSRD scope:

  • Raised thresholds — the threshold moves from 250 to 1,000 employees (combined with €50M turnover or €25M balance sheet). Result: about 80 % of companies initially subject to CSRD drop out of the mandatory scope.
  • Stop-the-clock — two-year postponement of waves 2 and 3 (first reports 2028 and 2029).
  • Simplified datapoints — EFRAG mandate to reduce the number of mandatory datapoints by about 40 %.

Consequence: many companies that thought they were entering wave 2 (2026) discover they are now outside the mandatory scope or postponed to 2028. But SFDR pressure, CRR3 banks, CSRD clients, public procurement, ESG rating agencies do not let up. NORMAXIS performs an individualised scoping diagnostic with an adapted strategy: stay outside the scope, publish voluntarily, or prepare for 2028.

Large company CSRD benchmarks

Key structuring elements.

1,000 employees

New Omnibus threshold

Instead of 250 initially

12 ESRS

Thematic standards

Filtered by double materiality

Limited assurance

Audit level 2025-2028

Reasonable from 2028-2029

ISO 17065

Independent third party

BPS · Efficarbone operated by IRICE

Large company CSRD FAQ

Frequently asked questions.

With the proposed Omnibus thresholds (1,000 employees + €50M turnover or €25M balance sheet), a company with 800 employees drops out of the mandatory scope, unless: listed on a regulated market, subsidiary of a CSRD group, or public-interest entity (bank, insurance). This does not mean zero reporting — indirect pressures (investor SFDR, CRR3 banks, wave 1 CSRD clients, public procurement) remain. NORMAXIS delivers a scoping diagnostic that integrates these indirect constraints.
ESRS 1 and 2 (cross-cutting — general requirements, governance, IRO) are always mandatory. ESRS E1 climate is presumptively material for almost every company — justifying its immateriality is very difficult. Others (E2 pollution, E3 water, E4 biodiversity, E5 circularity, S1-S4 social, G1 governance) are material depending on sector and double materiality. For a B2B services company, typically 4-6 ESRS are material; for an industrial company, 7-10. The materiality matrix documents the choice.
Three entry routes for E4. First, upstream supply chain — if your suppliers have a significant biodiversity impact (paper, textile, food, materials), the impact comes back to you via Scope 3 and dependencies. Second, owned real-estate portfolio — headquarters, branches, offices in sensitive areas. Third, indirect exposure — for a bank financing real estate, a consultancy with high-E4-impact clients. BPS diagnoses direct real-estate assets and documents dependencies via the value chain.
No — and that's precisely the trap. A sloppy double materiality produces a wobbly report: costly over-reporting, risky under-reporting before the auditor, year-1/year-2 inconsistencies, ungrounded transition plan. Sustainability auditors now systematically check method (stakeholder consultation, justified scoring, validating governance). A well-built materiality report is the most durable asset of the CSRD effort — it structures strategy and holds over time.
For a large company starting from scratch: 12 to 18 months for the first period (materiality 3-4 months + gap analysis 2-3 months + data collection and production 4-6 months + drafting and audit preparation 3-4 months). A company with an existing advanced CSR reporting: 6 to 9 months. Subsequent periods: 4 to 6 months in steady state. The initial investment is significant but largely capitalisable.
Three angles. First, proprietary tools as independent third party under ISO/IEC 17065 — BPS and Efficarbone produce opposable datapoints that a classic consulting firm cannot issue on its own (they are consultants, not certifiers). Second, technical field competence (ARKEMEP, ARKENOR) — when datapoints require physical measurements (thermal, acoustic, biodiversity), NORMAXIS produces them; the Big 4 subcontract. Third, integration — one contact for materiality + production + certification + audit preparation. The Big 4 and IT services have their strengths in financial consolidation and IT; NORMAXIS excels on technical substance.

To go further

Related pages.

NORMAXIS

CSRD pillar

Overview of the directive, 12 ESRS, schedule, Omnibus 2026.

Découvrir

NORMAXIS

SFDR & Taxonomy alignment

PAIs, Taxonomy alignment ratio, DNSH criterion 6.

Découvrir

Irice

BPS — Biodiversity Performance Score

Proprietary 70+ criteria tool, third party under ISO/IEC 17065.

Découvrir

Framing your CSRD reporting?

Post-Omnibus scoping diagnostic, sector-specific double materiality assessment, multi-ESRS gap analysis, datapoint production through proven methods, transition plans, sustainability-audit preparation. Engagement tailored to your sector.

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