The final version of the CSRD – How businesses should prepare

With Julien Denormandie, CIO of Sweep, and former French Minister for Agriculture

Julien, the CSRD has finally reached its definitive version. What do you think of this outcome after many months of debate?

This period of debate was long and intense, but the good news is that the CSRD remains in place despite the changes. While the number of companies covered has indeed been reduced, the reduction is less significant than what had been considered by the European Parliament in November (i.e. companies with more than 1,750 employees).

Despite the storm, the core foundations of the CSRD have held firm. It is now up to us to make it a regulation that is truly useful for companies, and that can then be progressively extended to a broader set of stakeholders in the years ahead.

What does this change in practical terms for the companies concerned?

The most visible changes relate to reporting thresholds and timelines. In concrete terms, the CSRD now applies to EU-based companies that exceed both 1,000 employees and €450 million in turnover. For these companies, the first report will be due in 2028, covering the 2027 financial year.

Companies based outside the EU fall within the scope of the CSRD if they have a European subsidiary generating at least €200 million in EU revenue, with consolidated EU revenue of at least €450 million. For these companies, the first report will be due in 2029, covering the 2028 financial year.

And what about the content of the ESRS? What happens to the 1,200 indicators?

EFRAG recently proposed a simplified version of the ESRS standards, which is expected to be formally validated in mid-2026. In practical terms, the number of mandatory indicators has been reduced from 1,144 to around 450, and the “voluntary” indicators have been removed altogether.

In addition, further simplifications have been proposed, including the principles of “Fair Presentation” and “Partial Scope,” as well as a streamlined report structure with a stronger focus on the General Disclosure Requirements (GDR). Without going into too much detail, the key takeaway is that the CSRD reporting burden will be reduced.

Has the CSRD therefore been stripped of its substance?

No, it has simply been made more efficient and more useful. Core principles such as double materiality and reporting on Policies, Actions, and Targets (PAT) remain in place, but the reporting process itself becomes more rational.

If I am a sustainability or CSR leader in a company subject to the CSRD, what should I be doing in the coming weeks and months?

My advice is to start as early as possible. The year 2026 is precisely the time to prepare. Begin setting up the project: which teams will be involved, what needs to be done, what data is required, and how it will be collected.

This remains a company-wide initiative that requires a genuine internal transformation.

Above all, approach this exercise as a way to strengthen your competitiveness. The CSRD will help you identify opportunities and mitigate risks through IROs, and improve your resilience to risks, including climate risks. In reality, you will be laying solid foundations for success in a future low-carbon economy.