The CSRD divides opinion on non-EU reporting
The Corporate Sustainability Reporting Directive (CSRD) is relevant to reporters beyond Europe, as it also requires large non-EU groups with significant EU business to report on their sustainability impacts. The European Financial Reporting Advisory Group (EFRAG) drafted their standard in early 2025, paused work while the EU’s Omnibus package made its way through, and has called for input on a revised version, the European Sustainability Reporting Standards for certain non-EU undertakings (ESRS-40a). EFRAG calls it the last piece of the CSRD.
Around 100 organisations responded. One argument that stands out relates to reducing reporting burden and increasing interoperability: many non-EU groups already report under International Sustainability Standards Board (ISSB) standards, and respondents including Japan’s Financial Services Agency want ESRS-40a to build on that, adding only clearly identified top-ups. One UK mapping of the national climate standard onto ESRS-40a ran to 17 pages. Another debate is over the “mixed approach,” which lets groups report non-climate impacts group-wide or only where they touch the EU. The mixture of scales could potentially be a source of confusion and of reduced comparability in the resulting data.
Reports must also be machine-readable. Digital tagging ensures that, for example, a pollution figure that only covers a group’s EU business is not erroneously compared by software with another group’s global figure as if the two were like-for-like. There remains a pressing need, however, for more effective ways to understand which sustainability concepts can and can’t be compared, and potentially identify priorities for adjustment. This is an area that XBRL International has been focussed on for some time, with a “concordance” proto-standard to permit various kinds of official mapping assertions unveiled at Data Amplified last week and to be the subject of a range of discussions at COP31 next week.
EFRAG aims to finalise the standard in January 2027 and submit it to the European Commission, which has the final vote, ahead of first reports in 2029.
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