{"id":9414,"date":"2026-03-17T13:00:32","date_gmt":"2026-03-17T12:00:32","guid":{"rendered":"https:\/\/www.trusteddecisions.com\/blog-new\/csrd-reporting-obligations-2026-what-will-change-in-the-legal-requirements-for-companies\/"},"modified":"2026-07-04T09:16:45","modified_gmt":"2026-07-04T07:16:45","slug":"csrd-reporting-obligations-2026-what-will-change-in-the-legal-requirements-for-companies","status":"publish","type":"blog-new","link":"https:\/\/www.trusteddecisions.com\/en\/blog\/csrd-reporting-obligations-2026-what-will-change-in-the-legal-requirements-for-companies\/","title":{"rendered":"CSRD reporting obligations 2026: What will change in the legal requirements for companies"},"content":{"rendered":"\r\n

The most important facts in brief<\/strong><\/h2>\r\n\r\n\r\n\r\n

Sustainability reporting is finally turning from an optional to a mandatory program for European SMEs and large corporations. With the extended CSRD reporting obligations that will take effect for many companies in 2026, the legal requirements for transparency in terms of sustainability, the environment and social responsibility are increasing massively. The EU is pursuing the clear goal of putting financial and non-financial performance indicators on an equal footing in legal and strategic terms. Companies that fail to prepare their controlling departments in good time for the implementation of the new data requirements risk not only compliance violations, but also a loss of trust among investors and customers.<\/p>\r\n\r\n\r\n\r\n

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From the NFRD to the CSRD: The new era of sustainability reporting<\/h2>\r\n\r\n\r\n\r\n

For a long time, the Non-Financial Reporting Directive (often referred to as the Financial Reporting Directive NFRD) provided the framework. In Germany, this old CSR Directive was transposed into national law by the CSR-RUG (CSR Directive Implementation Act). The problem: the regulations only affected a very small group of large capital market-oriented companies.<\/p>\r\n\r\n\r\n\r\n

With the introduction of the Corporate Sustainability Reporting Directive, this landscape is changing fundamentally. This new directive replaces the NFRD, drastically expands the group of companies affected and enormously tightens the content review obligation.<\/p>\r\n\r\n\r\n\r\n

The Corporate Sustainability Reporting Directive (CSRD) at a glance<\/h3>\r\n\r\n\r\n\r\n

The primary aim of the legislation is to effectively prevent greenwashing and provide stakeholders with standardized, comparable data. The focus is no longer just on soft declarations of intent, but on hard, auditable KPIs.<\/p>\r\n\r\n\r\n\r\n

Companies must disclose in detail how their business models affect the environment and, conversely, what financial risks climate change poses for their own business model (principle of double materiality). Controlling is thus moving to the center of corporate management, as non-financial data must now be recorded and externally audited with the same rigor as the traditional annual financial statements.<\/p>\r\n\r\n\r\n\r\n

Current developments: “Stop the Clock” and omnibus initiative<\/h3>\r\n\r\n\r\n\r\n

The regulatory landscape in Brussels is highly dynamic. In order not to overburden the economy in economically challenging times, European politicians have recently made some adjustments.<\/p>\r\n\r\n\r\n\r\n

One prominent example is the so-called “Stop the Clock”<\/strong> decision. This postpones the publication of certain sector-specific standards (which were actually planned earlier) by two years to mid-2026. At the same time, the Omnibus Directive aims to streamline general reporting obligations at EU level by around 25% in order to avoid unnecessary bureaucracy and duplication.<\/p>\r\n\r\n\r\n\r\n

But beware: despite this selective relief through “Stop the Clock” or the omnibus initiative, the strict foundation of the CSRD reporting obligations<\/strong> remains untouched. The time buffer should urgently be used by companies to set up internal systems for data collection now.<\/p>\r\n\r\n\r\n\r\n

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Scope of the CSRD: Who is required to report in 2026?<\/h2>\r\n\r\n\r\n\r\n

The EU is gradually extending the scope of the CSRD in order to give businesses the time they need to adapt. Exactly who has to report and when depends on the size and capital market orientation. For controlling, this means that it is absolutely essential to assess your own status quo in good time.<\/p>\r\n\r\n\r\n\r\n

Thresholds: Large companies and the extension of the obligation (wave 2)<\/h3>\r\n\r\n\r\n\r\n

While in so-called wave 1 (for the 2024 financial year, 2025 reports) initially only those groups that were already subject to the old NFRD were required to report, wave 2 now brings the real bang for the buck for the broad market.<\/p>\r\n\r\n\r\n\r\n

From the 2025 financial year – with the publication of the reports in 2026 – tens of thousands of additional large companies across Europe will fall within the scope of application. A company is considered large if it exceeds at least two of the following three thresholds on two consecutive reporting dates:<\/p>\r\n\r\n\r\n\r\n

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  • more than 250 employees<\/strong><\/li>\r\n\r\n\r\n\r\n
  • more than 50 million euros in net sales (recently increased by the EU Commission due to inflation)<\/strong><\/li>\r\n\r\n\r\n\r\n
  • more than 25 million euros in total assets<\/strong><\/li>\r\n<\/ul>\r\n\r\n\r\n\r\n

    Indirect impact on small and medium-sized enterprises (SMEs) in the supply chain<\/h3>\r\n\r\n\r\n\r\n

    Even if small and medium-sized enterprises (SMEs) are often not directly legally obliged at first glance, they are feeling the effects of the extension of the directive enormously. The reason for this is the so-called “trickle-down effect” in the supply chain.<\/p>\r\n\r\n\r\n\r\n

    Large corporations require detailed Scope 3 emissions data and ESG key figures from their suppliers in order to be able to complete their own sustainability reports in compliance with the law. This means that SMEs are in fact indirectly forced to provide this information. For capital market-oriented SMEs, the direct, legal reporting obligation will then take effect in wave 3 at the latest.<\/p>\r\n\r\n\r\n\r\n