What do I need to report under CSRD?
Direct answer
Reporting under the CSRD means accounting for sustainability in the management report according to the European ESRS standards. You only cover topics that are material to your business, identified through a double materiality assessment. For most companies this includes climate and energy: energy consumption, energy mix and greenhouse gas emissions in scope 1, 2 and 3. Since the Omnibus amendment, the obligation only applies to large undertakings.
- Clear definition
- Data-driven assessment
- Risks and opportunities visible
- Practical next steps
What do I need to report under CSRD: scattered information versus Energy Intelligence
The CSRD is the European directive that makes sustainability reporting mandatory for large undertakings. The rules were simplified considerably in 2025 and 2026: the 'stop the clock' directive postponed deadlines by two years and the Omnibus directive raised the thresholds substantially. Many companies that were preparing now fall outside the obligation. The topic remains relevant nonetheless: facility managers and finance leads increasingly receive questionnaires from large customers that must report themselves and need energy data from their supply chain.
- Step 1: check whether the obligation applies to you. After the Omnibus amendment, only undertakings with more than 1,000 employees and net turnover above 450 million euros must report.
- Step 2: carry out a double materiality assessment. It determines which ESRS topics you need to cover, from climate change to your own workforce.
- Step 3: collect your energy data and emissions in scope 1, 2 and 3. Metered consumption and generation data form the basis of the climate section.
Insight
Traditional approach
Information is scattered across portals, documents, invoices or separate spreadsheets.
Modern approach
Data, context and interpretation are brought together into a clear decision picture.
Decision-making
Traditional approach
Choices are made based on averages, assumptions or occasional analyses.
Modern approach
Scenarios, KPIs and current measurement data make the trade-off more concrete and repeatable.
Follow-up
Traditional approach
Actions often stay non-committal or disappear into separate reports.
Modern approach
Follow-up actions, monitoring and reporting are linked to the same energy data.
Who has to report now?
The Omnibus directive of February 2026 sharply reduced the scope of the CSRD. The obligation now applies to undertakings with on average more than 1,000 employees and net turnover above 450 million euros. Both criteria must be met at the same time. Listed SMEs, previously the third wave, are entirely outside the mandatory scope. Companies that already reported but stay below the new thresholds fall outside the obligation from financial year 2027; Member States may exempt them for earlier financial years. Companies above the thresholds report under the simplified standards for financial year 2027 at the latest. The Netherlands transposes the directive into national law; follow the current guidance from RVO and the central government. If you are unsure of your own position, start with a simple group-level test: headcount and turnover on a consolidated basis.
- Thresholds after Omnibus: more than 1,000 employees and more than 450 million euros net turnover, both at once
- Listed SMEs are no longer obliged to report
- Companies not yet reporting start with financial year 2027 at the latest
- Large non-EU groups with substantial EU turnover fall under separate thresholds
What goes into the sustainability statement?
The sustainability statement is part of the management report and follows the ESRS. In July 2026 the European Commission adopted a simplified version with substantially fewer mandatory datapoints. The core remains double materiality: you report on topics your company has an impact on and on topics that affect your company financially. For almost every reporting undertaking, climate change is material. This covers your energy consumption and energy mix, greenhouse gas emissions in scope 1 (own emissions), scope 2 (purchased energy) and scope 3 (value chain), plus your targets and a transition plan if you have one. Reliable metering data from your connections is essential here: companies with quarter-hourly data and consumption records in order avoid a great deal of detective work afterwards.
- Double materiality determines which topics you cover
- Climate and energy: consumption, energy mix and emissions in scope 1, 2 and 3
- The simplified ESRS of July 2026 apply mandatorily from financial year 2027
- An external auditor reviews the statement with limited assurance
What does this mean for SMEs and suppliers?
If your company falls outside the obligation itself, you will often encounter the CSRD through your customers. Large reporting undertakings need data from their value chain for their scope 3 emissions and send questionnaires to suppliers for that purpose. The Omnibus directive limits this trickle-down effect: the information they may request from value chain partners with up to 1,000 employees is in principle limited to what the voluntary VSME standard asks for. That standard is a light, voluntary reporting format for SMEs, with basic data on matters such as energy consumption and emissions. A practical step-by-step approach: first map your own energy consumption per connection, then calculate your scope 1 and scope 2 emissions, and finally establish a fixed procedure so you can answer customer requests quickly and consistently.
- Your customer's scope 3 turns your energy data into value chain data
- The voluntary VSME standard is the reference point for questions to SMEs
- Large customers may in principle not request more than the VSME standard covers
- One fixed dataset prevents duplicate work across multiple customer requests
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