CSRD updates: changes and lessons learned from the first wave of sustainability reporting

CSRD updates: changes and lessons learned from the first wave of sustainability reporting

The first companies are finalizing their sustainability reporting. What can we learn from these enterprises? And what does the omnibus package mean for CSRD?

Rebekah Mays
By
Rebekah Mays
February 4, 2025
# min read
Table of contents

Link

CSRD updates: changes and lessons learned from the first wave of sustainability reporting

As the first wave of companies is preparing to publish their Corporate Sustainability Reporting Directive (CSRD) reports, a new era of sustainability data disclosure is taking shape. And if your reports aren’t due this year, they will be coming up soon.

Companies that are reporting in 2026 and 2027 still have time to prepare. However, implementing a solid CSRD strategy requires careful planning and resource allocation. 

Specifically, it’s important to consider your reporting timeline, potential changes to CSRD implementation, and build on the lessons learned from companies that have gone through the process. 

In this article, we’ll share learnings from the first wave of reporting companies and tips from our climate expert team, so you can move forward with confidence.

‍

CSRD timeline: when are your reports due? 

‍

First things first: when do you need to comply with these reporting standards?

CSRD reports go hand-in-hand with financial reports, so your specific due date will depend on your reporting wave and your fiscal year.

According to a notice prepared by the EU Commission, companies must publish reports within four months of the end of their fiscal year. 2025 is the first mandatory year of reporting for the first wave of companies, so you can expect to see most reports published in April for companies whose fiscal year ended in December.

The next wave of in-scope companies must report in 2026 on the 2025 fiscal year, with the following wave of companies reporting in 2027 on fiscal year 2026.

Here’s the specific breakdown:

Wave 1, Reporting in 2025 (FY 2024) 

As of January 2025, large companies with 500+ employees who were previously subject to the Non-Financial Reporting Directive are preparing their reports for 2025 publication.  

Wave 2: Reporting in 2026 (FY 2025)

The next wave of companies will report in 2026 based on the 2025 fiscal year. This group includes large EU companies that meet at least two of these criteria:

  • €50 million in net turnover
  • €25 million in assets
  • 250 or more employees

Wave 3: Reporting in 2027 (FY 2026)‍

This wave of companies reports in 2027 on fiscal year 2026. This group includes listed European SMEs and select financial institutions.Wave 4: Reporting in 2029 based on FY 2028Finally, this wave extends to non-EU companies with a net turnover in the EU of €150+ million in two consecutive years that own any of the following:

  • An EU-based branch with securities listed on an EU-regulated market exchange
  • An EU office with €40+ net turnover
  • A Large EU-based undertaking

This final group must report in 2029 based on the 2028 fiscal year.

‍

CSRD updates: no big changes yet

No major changes to the CSRD or the reporting standards were published in 2024. Still, there are a few updates that sustainability stakeholders should keep in mind:

‍

Sector-specific guidelines delayed

The EU Commission was planning to release sector-specific guidelines in 2024. However, the commission has pushed these back to 2026. You can keep an eye on these updates via the “policy making timeline” on the European Commission’s corporate sustainability reporting page.  

‍

Some EU Member states are catching up

A few EU member states, including Germany and the Netherlands, missed the July 2024 deadline to bring CSRD into national law. The EU Commission sent letters to these member states urging them to take action.

Even if your country has not transposed the law nationally, remember that the CSRD is a binding EU law regardless of national implementation status. Cozero recommends sticking to published deadlines to avoid any penalties or stakeholder backlash.

‍

New resources available

EFRAG, the EU’s sustainability reporting advisory body, published a number of resources for reporting companies, including answers to frequently asked questions and a “readiness study.” These resources aim to prepare sustainability stakeholders with key takeaways and support for preparing.

‍

CSRD 2025 updates: “Omnibus package” to potentially simplify sustainability reporting

‍

The largest changes to the CSRD, however, may be still to come.

The European Commission has announced they are planning an “Omnibus proposal”, a legislative update aimed at simplifying and reducing the administrative burden of sustainability, due diligence, and taxonomy requirements by 25% for firms and 35% for SMEs. The Omnibus proposal is part of the “Competitiveness Compass,” a plan to boost Europe’s competitiveness.

More details on the omnibus package should be available at the end of February 2025. It’s unclear what these changes look like and whether the proposed changes would simplify reporting requirements, or “water down” the reporting framework as some critics claim. While some EU Member States are pushing for this package, several corporate stakeholders from large brands including Unilever, Mars, and Nestlé are publicly urging legislators not to weaken existing sustainability legislation.

Esther Snijder, Climate Expert at Cozero, agrees that while the implications of the omnibus package aren’t yet clear, she expects changes to emerge later in 2025 and 2026.

“The reporting standards have only been finalized relatively recently,” Esther says. “After the first half of 2025, many more companies will report, so I think we’ll see changes once more companies start reporting.” 

‍

Despite the uncertainty, Cozero recommends moving forward with reporting as planned, and keeping an eye on potential deadline changes.

‍

‍

Lessons learned and key takeaways from early reporters 

‍

While most in-scope companies are still finalizing the first round of reporting, one thing is clear: The CSRD is one of the most comprehensive sustainability reporting frameworks today. 

Reporting takes time, often several months at a minimum, if not multiple years. 

What can sustainability stakeholders learn from companies who are finalizing their first reports? Thanks to EFRAG’s “readiness study” and analysis from Cozero partner Sunhat, we have a few takeaways.

‍

‍

Lesson 1: The Double Materiality Assessment is valuable for business strategy

‍

The Double Materiality Assessment is a key aspect of CSRD reporting, requiring companies to identify material topics from both an “outside-in” and “inside-out” approach.

According to the EFRAG readiness study, 85% of companies plan to integrate results of the Double Materiality Assessment into their overall business strategy. This finding shows that CSRD reporting is valuable to the company as a whole, and not only for compliance. 

PostNL, which will report in 2025, began preparations in 2022. Over three years, they’ve worked to understand requirements, conduct assessments and gap analyses, and prepare reports. A key part of the process was updating their material ESG topics published in past reports. Pictured: PostNL key material ESG topics, from their Annual Report 2023.

Takeaway for your firm

It’s worth taking the time to get the Double Materiality Assessment right, as it forms the basis for all your CSRD reporting initiatives. Companies like Kraft Heinz and PostNL completed the materiality assessment as one of the first steps of their reporting, using the results to guide the rest of the planning process. 

If you’re reporting in 2026 based on fiscal year 2025, there’s still time to go through this process. However, the Double Materiality Assessment and value chain mapping should likely be high-priority items in Q1 of this year, if you haven’t yet completed them.

‍

‍

Lesson 2: Data granularity is a challenge 

‍

Another key challenge revealed in the EFRAG readiness study is the large amount of detail needed for reporting on specific data points. Currently, just 10% of companies are aiming for full disclosure of data points for all material topics, while 75% are using a phase-in option to gradually increase the level of detail in their data reporting.

Esther Snijder, Climate Expert at Cozero, agrees that this data collection is one of the most time-consuming aspects of CSRD.

“It's a lot of data you need to gather, and this data should be gathered throughout the year,” she says. “Starting that process is extremely important.”

This will be custom for each company, but she points out that something as simple as collecting the electricity used across offices requires processes to collect information, translate this into CO2 equivalents, and report on these metrics. 

“The good news is that with each year, as you do it more often and start to put these systems in place, collecting this data will get easier,” she adds.

‍

Takeaway for your firm

A phased-in approach to granularity might make sense for your enterprise, but don’t forget to prioritize detailed data points for material topics.

Keep in mind that the CSRD’s climate reporting requirements are particularly comprehensive and will be relevant for most companies. As part of ESRS E1, firms must not only disclose greenhouse gas emissions, but also publish a detailed climate transition plan. Since most companies will likely consider ESRS E1 climate change material, it’s wise to seek specialized support in climate data reporting. 

The right support can significantly streamline data collection, as seen with Cozero’s partnership with packaging specialist TRICOR, which resulted in a streamlined compliance reporting for CSRD, CDP and EcoVadis.

The bottom line is to go deep on material topics, rather than providing high-level information across all topics.

‍

‍

Lesson 3: Enterprises recognize the need for IT transformation

‍

Another major takeaway is the growing need for companies to embrace an IT transformation. EFRAG’s study revealed that 85% of companies recognize their current systems aren’t equipped to handle new ESG reporting requirements.  

This is particularly clear in supplier data collection, where traditional IT systems often fall short of reporting needs.

‍

In 2024, Cozero customer Vodafone is prioritizing the “quality and timeliness” of their ESG data, working with partners to accurately track Scope 3 emissions based on supplier data. Pictured: Vodafone Climate Transition Plan 2025-2027, page 7.

‍

‍Takeaway for your firm

While becoming a data-driven organization is no easy feat, it all starts with bringing in the right tools and support systems in place to speed up the transformation. 

Cozero partners with companies to help them make this data transformation, supporting companies in manufacturing and logistics with key tasks like data-based decarbonization strategy, granular emissions data collection, and automated emissions calculations via its Climate Action Platform.  

The benefits of embracing this IT transformation go far beyond CSRD compliance, as this transformation is key to becoming a more resilient company in 2025 and beyond.

‍

Prepare for reporting in 2026 and beyond

‍

CSRD compliance requires significant resources, but early reporters are showing the process delivers valuable insights for the company as a whole. 

For companies reporting in 2026 and 2027, the Double Materiality Assessment and value chain mapping are likely the first steps to prioritize. 

Despite uncertainty around potential CSRD simplifications, the experiences of large companies show that building robust reporting systems takes time, often multiple years.

Starting now not only supports compliance but also positions your organization for long-term success in sustainability reporting.

If you’re looking for support on climate reporting requirements, Cozero’s end-to-end Climate Action Platform provides the tools you need for granular climate data collection, decarbonization strategy, and emissions management and reporting.

Through Cozero’s recent partnership with Sunat, the team has expanded CSRD capabilities to offer even more comprehensive support for your sustainability reporting journey.

‍

‍

Resources

‍

‍

Download for free

Related articles

Best practices in carbon accounting: How to measure your corporate carbon footprint
Carbon accounting

Best practices in carbon accounting: How to measure your corporate carbon footprint

January 22, 2025
Driving data granularity and supplier engagement: insights from Hapag-Lloyd's Manager of Supplier Sustainability
Logistics
Decarbonization

Driving data granularity and supplier engagement: insights from Hapag-Lloyd's Manager of Supplier Sustainability

November 11, 2024
What’s really behind the Scope 3 data dilemma, and how do we solve it?
Carbon accounting

What’s really behind the Scope 3 data dilemma, and how do we solve it?

November 7, 2024
Regulations