CASE STUDIES published on 20 Apr 2023

Sustainability Rulebook: The Corporate Sustainability Reporting Directive


What is the Corporate Sustainability Reporting Directive? 

The Corporate Sustainability Reporting Directive (CSRD) requires large and/or listed companies to publish regular reports on the social and environmental risks they face, and on how their activities impact the rights of people and the environment. The aim is to enable investors, civil society organisations, consumers and other stakeholders to evaluate how sustainable these companies are.

The CSRD is part of the European Green Deal – a set of policy initiatives by the European Commission. The overarching aim is to make the European Union fit to reduce net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels, and climate-neutral by 2050.

What are the main differences between the CSRD and the NFRD?

The CSRD amends the Non-financial Reporting Directive (NFRD), expanding the scope of these reporting requirements to a broader set of large companies, as well as listed SMEs. The NFRD applies only to so-called “public-interest entities”, such as listed companies, banks, or insurance companies, [1]  with more than 500 employees. As a result, the companies needing to report on non-financial issues goes from approximately 11 700 under the NFRD to approximately 50 000 companies under the CSRD.

The CSRD also modernizes and strengthens the rules about the social and environmental information that companies must report on by specifying that the information must be relevant, comparable, reliable, and accessible. Companies will have to report according to binding standards. By contrast, under the NFRD, large companies were free to choose the standard for publishing sustainability information. Under the NFRD auditing is voluntary. The CSRD makes it mandatory. 


Who does the CSRD cover?

Whether a public service media (PSM) organisation will fall within the scope of the CSRD depends on its legal form. PSM organisations established under public law will not be covered. But many PSM that are established under private law will be. For instance, a PSM that is incorporated as a joint stock company will be covered even if it is entirely owned by the State.

Precisely which kind of private legal entities will be required to report varies across Member States. A list of the relevant types of companies can be found in Annex I and Annex II of the EU Accounting Directive 2013/34/EU. Of those companies, the CSRD only requires companies that fulfill any of the following criteria to report on sustainability:

  • all listed companies on the EU regulated market, including listed SMEs (but not micro-enterprises)
  • all large companies that exceed two of the three following criteria: 
    • 250 employees during the financial year 
    • balance sheet of more than EUR 20 million
    • net turnover of more than EUR 40 million  
  • non-EU companies generating a net turnover of more than EUR 150 million and having a subsidiary in the EU that follow the criteria applicable to EU companies or a branch in the EU generating more than EUR 40 million net turnover

The CSRD doesn’t apply to me – why should I care?

Many PSM will not be covered by the CSRD because they are public entities. Still, they may choose to use the same reporting standards on a voluntary basis. Requests for sustainability information from companies you are dealing with (e.g., banks, or companies you supply) are likely to increase once the CSRD becomes applicable to them. As a result, collecting and disclosing sustainability information will likely become a common business practice in the media sector. Using CSRD standards could make it easier to report the necessary information to banks, clients, partners and other stakeholders.

Sustainability is also becoming an essential part of consumer decisions, with increasing expectation on organizations to be sustainable. [2] Working on sustainability is a good way to create social impact and a positive effect on a PSM’s brand value. [3] It also has a positive impact on reach, both in terms of general audience and young audiences, and leads to higher audience satisfaction. [4] At the same time, many Europeans are concerned about false sustainability claims and do not trust mere brand pledges. [5] PSM are facing increasing public pressure to justify their legitimacy by providing evidence of their social impact. [6] Therefore, sustainability reporting according to uniform standards can increase transparency and comparability, provide a basis for better, dialogue and communication with audiences and other stakeholders, improve your reputation and attract young talent.

When will the CSRD enter into effect ?

The European Commission adopted the CSRD in late 2022. The Directive entered into force in January 2023. The rules will start applying between 2024 and 2028:

  • From 1 January 2024 for large public-interest companies (with over 500 employees) already subject to the non-financial reporting directive, with reports due in 2025.
  • From 1 January 2025 for large companies that are not presently subject to the non-financial reporting directive (with more than 250 employees and/or €40 million in turnover and/or €20 million in total assets), with reports due in 2026.
  • From 1 January 2026 for listed SMEs and other undertakings, with reports due in 2027. SMEs can opt-out until 2028.

The rules introduced by the NFRD remain in force until companies must apply the new rules of the CSRD.

What are the reporting requirements?

Companies must disclose the impact of sustainability topics on the company’s value (financial materiality), impact on the economy, the environment, and people (impact materiality), and how they are interconnected. Companies must provide qualitative and quantitative information on their: 

  • business model and strategy including its resilience to sustainability risks, opportunities, and transition plans 
  • targets and the progress made to achieve those targets
  • role of the administrative, management and supervisory bodies and their expertise and skills to fulfil these roles
  • policies, processes, and incentive schemes 
  • adverse impacts and actions to prevent, mitigate and remediate them
  • principle risks and their management 

Relevant information includes intangibles, including intellectual, human, as well as social and relationship capital. Information about the company’s value chain will also be required where appropriate. The information should be forward-looking and retrospective, qualitative and quantitative, and cover short, medium and long-term horizons.

What reporting standards will need to be followed?

Companies subject to the CSRD will have to report according to European Sustainability Reporting Standards (ESRS). The draft standards are developed by the EFRAG (European Financial Reporting Advisory Group), a private association established in 2001 with under the auspices of the European Commission. Its Member organisations are European stakeholders, national organisations and civil society organisations. EFRAG provides technical advice to the European Commission in the form of fully prepared draft EU Sustainability Reporting Standards and/or draft amendments to these Standards.

The Commission should adopt the first set of cross-cutting standards and standards for all sustainability topics (i.e., environment, social and human rights, and governance) by mid-2023, based on the draft standards published in November 2022. Sector-specific standards are expected to follow by 30 June 2024. [7] With the carbon footprint of the video industry having surpassed that of the aviation industry, [8] the Commission may adopt specific standards for the (audiovisual) media sector.

How should the report be submitted?

Sustainability information must be included in the management report and digitalized as companies will be required to prepare their financial statements and their management report in a single electronic reporting XHTML format. [9]

What about the mandatory audits?

The CSRD also requires companies to audit the sustainability information they disclose. The information will be subject to mandatory external “limited” assurance, but is expected to shift towards a more rigorous “reasonable” assurance requirement at a later stage.

Contact Details

Sophia Wistehube
Legal Counsel
Legal & Policy

Related Links

Sustainability Summmit 2023
EBU Climate Journalism that Works
Sustainability: An Outline of Public Service Media Involvement


[1] Member States may designate additional types of public-interest entities.

[2] EBU Media Intelligence Service, (January 2023, Member exclusive).

[3] EBU Media Intelligence Service, Environmental Sustainability at Public Service Media, (forthcoming, Member exclusive).

[4] Ibid.

[5] Ibid.

[6] EBU Media Intelligence Service, Unpacking Social Impact, (February 2023, Member exclusive).

[7] Guidance may come from the Media and Audiovisual Action Plan (MAAP) Acton 6 which aims to help the audiovisual media industry become climate neutral by 2050 by facilitating the exchange of best practices. A group of organisations have agreed to work together towards the development of a unified measurement methodology of CO2 emissions, that will contribute to the reduction of carbon emissions.

[8] Futuresource Consulting, Sustainability in Video Entertainment: 2022 Industry Update (November 2022).

[9] Article 3 of the Commission Delegated Regulation (EU) 2019/815.