CSRD — Sustainability reporting
EU Directive 2022/2464, ESRS standards, double materiality — the new sustainability disclosure regime for European companies

The CSRD (Corporate Sustainability Reporting Directive) imposes standardised and audited sustainability reporting on large European companies, listed mid-caps and listed SMEs. The framework is built on twelve ESRS standards, the double materiality principle, and articulation with SFDR and the EU Taxonomy. The 2026 Omnibus directive reduces the scope of companies subject to reporting and simplifies the data requirements. NORMAXIS supports framing, indicator production and the transition plan — with confirmed specialisation on ESRS E4 biodiversity through the proprietary BPS tool operated by IRICE as an independent third party.

Frame a CSRD reporting See our ESRS E4 biodiversity practice

Regulatory framework

From NFRD to CSRD, and now to Omnibus.

The CSRD directive (2022/2464/EU) of 14 December 2022 replaces the NFRD (2014/95/EU) for non-financial reporting. Transposed into French law by ordinance no. 2023-1142 of 6 December 2023 and its implementing decree, it is codified at articles L.232-6-3 to L.232-6-8 and L.22-10-36 of the French Commercial Code.

The 2026 Omnibus directive (proposal adopted by the European Parliament) revises the scope of companies subject to reporting: raised thresholds, postponed entry into force for some waves, simplified data points. The 2026-2028 framework remains in motion — continuous monitoring is essential.

The CSRD framework articulates with:

  • ESRS (European Sustainability Reporting Standards) — 12 standards drafted by EFRAG and adopted by the European Commission (Delegated Regulation EU 2023/2772): two cross-cutting (ESRS 1 and 2), five environmental (E1 to E5), four social (S1 to S4), one governance (G1).
  • SFDR (Sustainable Finance Disclosure Regulation) — EU Regulation 2019/2088 for financial actors: PAI (Principal Adverse Impacts), articles 6/8/9.
  • EU Taxonomy (Regulation EU 2020/852) — classification of sustainable economic activities and DNSH (Do No Significant Harm) criterion.
  • Article 29 LEC (French Energy-Climate Act 2019-1147) — French specific obligation for institutional investors, articulated with SFDR.

Entry-into-force schedule

Four successive waves — revised by Omnibus.

Wave 1 — FY 2024

Companies already under NFRD (published in 2025)

Companies previously subject to NFRD — large public-interest entities with more than 500 employees — published their first CSRD report in 2025 on FY 2024. First large-scale field test.

Wave 2 — FY 2025

Large companies (published in 2026)

Large companies under the accounting directive: 2 out of 3 criteria — 250+ employees, €50M turnover, €25M balance sheet. First CSRD reporting in 2026. Omnibus raises the thresholds — some mid-caps initially in scope drop out.

Wave 3 — FY 2026

Listed SMEs (published in 2027)

SMEs listed on a regulated market: simplified reporting (ESRS LSME standard being finalised) tailored to their resources. Omnibus postpones this wave to 2028 or 2029 — schedule being clarified.

Wave 4 — FY 2028

Non-EU groups with significant EU activity

Parent companies outside the EU generating more than €150M of turnover in the EU via a subsidiary or branch. Consolidated reporting at group level under the ESRS NESRS standard (Non-EU Sustainability Reporting Standards).

The 12 ESRS standards

Two cross-cutting + ten thematic.

ESRS are the opposable framework for CSRD reporting. Drafted by EFRAG and adopted by the European Commission through Delegated Regulation EU 2023/2772 of 31 July 2023. Each thematic standard applies if material under the double materiality assessment.

Cross-cutting

ESRS 1

General requirements: reporting principles, double materiality, scope, quality of information.

Cross-cutting

ESRS 2

General disclosures: governance, strategy, IRO management (impacts, risks, opportunities).

Environment

ESRS E1

Climate change: transition plan, Scope 1-2-3 emissions, energy consumption.

Environment

ESRS E2

Pollution: air, water, soil, substances of concern.

Environment

ESRS E3

Water and marine resources: consumption, withdrawals, discharges.

Environment — NORMAXIS specialty

ESRS E4

Biodiversity and ecosystems: impacts, dependencies, biodiversity transition plan. Operated through the BPS tool by IRICE.

Environment

ESRS E5

Resource use and circular economy: material flows, waste, circularity.

Social

ESRS S1

Own workforce: employment, health and safety, social dialogue, diversity.

Social

ESRS S2

Workers in the value chain: working conditions of subcontractors and suppliers.

Social

ESRS S3

Affected communities: impacts on local communities, human rights, indigenous peoples.

Social

ESRS S4

Consumers and end-users: safety, consumer rights, access to information.

Governance

ESRS G1

Business conduct: ethics, lobbying, payments to authorities, whistleblowers, anti-corruption.

NORMAXIS specialty

ESRS E4 biodiversity via the proprietary BPS tool.

ESRS E4 (biodiversity and ecosystems) is the most challenging standard to document — biodiversity reporting is recent, input data are scarce, sector-specific frameworks are missing. NORMAXIS operates BPS (Biodiversity Performance Score), a proprietary biodiversity diagnostic tool structured around 70+ criteria across three phases (baseline, design, operation), delivered by IRICE as an independent third party under ISO/IEC 17065.

BPS directly produces the indicators required by ESRS E4: dependencies on ecosystem services, biodiversity impacts, condition of operated sites, biodiversity transition plan. The diagnostic is documented, comparable across portfolio assets and between reporting periods. It articulates with SFDR PAI 7 (sensitive areas), EU Taxonomy DNSH criterion 6 (biodiversity), TNFD (Taskforce on Nature-related Financial Disclosures) and the French article 29 LEC.

Discover BPS at IRICE →

Our engagements

How NORMAXIS supports a CSRD reporting.

Double materiality assessment

Identification of IROs (impacts, risks, opportunities) per ESRS standard, stakeholder consultation, materiality matrix, determination of applicable thematic standards.

Gap analysis

Stocktaking of available data versus ESRS requirements. Identification of data to collect, tools to implement, competences to mobilise. Costed roadmap.

ESRS E4 biodiversity production

BPS diagnostic on the relevant assets (operated by IRICE as third party), consolidation at group level, drafting of E4 indicators, biodiversity transition plan.

ESRS E1 climate production

Scopes 1-2-3 carbon footprint, climate resilience analysis, 1.5°C-aligned transition plan, articulation with the Efficarbone tool for construction operations.

SFDR / Taxonomy articulation

For financial and real-estate companies: coherence between CSRD, SFDR PAI, Taxonomy eligibility, DNSH criteria. Article 8 or 9 SFDR product files.

Sustainability audit preparation

The CSRD report is subject to limited assurance by an independent auditor. Audit trail preparation, process documentation, response to auditor queries.

CSRD benchmarks

Key structuring elements.

2022/2464

CSRD directive

Replaces NFRD 2014/95

12 ESRS

Mandatory standards

Delegated Regulation EU 2023/2772

Omnibus 2026

Simplification underway

Raised thresholds, revised schedule

ESRS E4

BPS / IRICE specialty

70+ biodiversity criteria — independent third party

CSRD FAQ

Frequently asked questions.

Three cumulative criteria for large companies (wave 2): more than 250 employees, turnover above €50M, balance sheet above €25M. Meeting 2 out of 3 is enough. For listed SMEs (wave 3): the wave is postponed to 2028 or 2029 by Omnibus. Omnibus also raises the general thresholds — the final scope is being adopted. NORMAXIS delivers an updated scoping diagnostic.
A central principle of CSRD. Each thematic ESRS standard (E1 to E5, S1 to S4, G1) must be analysed along two axes: impact materiality (how the company impacts society and the environment) and financial materiality (how sustainability matters affect the company financially). Only topics material on either axis must be reported.
For the first waves: limited assurance carried out by a statutory auditor or an independent third-party body. By 2028, assurance will move to reasonable assurance comparable to financial audit. Preparation for that shift starts from the very first reporting periods.
CSRD produces the data that SFDR consumes. Financial actors subject to SFDR (asset managers, funds) must disclose their PAI (Principal Adverse Impacts) — 14 mandatory and 2 optional indicators per category. These PAIs are computed from the CSRD data of investee companies. A non-CSRD company forces the financial manager to extrapolate — hence the pressure from investors for complete CSRD data, even on non-listed SMEs not formally in scope.
Specialisation on ESRS E4 biodiversity via the proprietary BPS tool (Biodiversity Performance Score), operated by IRICE as an independent third party under ISO/IEC 17065. BPS structures the diagnostic around 70+ criteria across three phases (baseline, design, operation), which directly produces ESRS E4 indicators with documented and comparable working method. Natural articulation with SFDR PAI 7, EU Taxonomy DNSH criterion 6, TNFD, French article 29 LEC. For E1 climate: articulation with Efficarbone (construction sites) and the RE2020 thermal study (new buildings).
For a first complete set-up (double materiality + data collection + indicator production + report drafting + audit preparation): 8 to 14 months depending on group complexity, number of entities, data availability. Well-prepared companies (with an advanced existing CSR reporting) can be ready in 6 months. Those starting from scratch should plan 12 to 18 months for the first reporting period.
The Omnibus directive (European Commission proposal February 2025, Parliament adoption during 2026) aims to simplify the CSRD: (1) raised thresholds for in-scope companies (some mid-caps drop out), (2) postponement of the listed SME wave, (3) simplification and reduction of mandatory datapoints, (4) focus on material indicators. A simplified but still substantial framework.
Yes. It is included in the sustainability section of the consolidated management report, published with the annual accounts. It is also transmitted in digital XBRL format to the European Single Access Point (ESAP) from 2027-2028. It is accessible to investors, employees, customers, NGOs, public authorities. Its quality directly influences reputation, cost of capital and access to certain public procurement markets.

CSRD ecosystem

Linked NORMAXIS pages.

NORMAXIS

SFDR & EU Taxonomy alignment

14 mandatory PAIs, articles 8/9, 6 Taxonomy objectives, DNSH, minimum safeguards.

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Irice

BPS — Biodiversity Performance Score

Proprietary 70+ criteria tool for ESRS E4 biodiversity. Operated by IRICE as third party under ISO 17065.

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NORMAXIS

Ecological expertise

Fauna-flora ecological surveys, ERC sequence, biodiversity baseline studies — operational ground floor of ESRS E4.

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Framing your CSRD reporting?

Double materiality assessment, gap analysis, ESRS indicator production (E4 biodiversity specialty via BPS), transition plan, audit preparation. Engagement tailored to your entry-into-force wave.

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