June 25, 2025

Sustainability reporting in the EU

US companies could be impacted by sustainability reporting and due diligence requirements in the EU – notably the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).

Get grounded, stay ahead

While the CSRD and CSDDD have been adopted into EU law, an Omnibus package introduced in February 2025 is set to make substantive changes to both directives. For a foundational overview of the CSRD and CSDDD, including changes introduced by the Omnibus Stop-the-clock directive and the European Commission’s (EC) proposed Content directive, read our Hot Topics linked below. For the latest developments on all the moving parts of EU sustainability reporting, including Omnibus updates, regularly visit this page and check the timelines below.

EU developments – at a glance

US companies – here’s what matters most
The Stop-the-clock directive gives most US companies an extra two years to prepare for CSRD reporting. It’s not yet clear what that reporting will look like and who will need to report. The European Financial Reporting Advisory Group (EFRAG) is working on simplifying ESRS while the European Parliament and Council work through proposals to revise CSRD scoping. While it remains uncertain what the scoping and reporting revisions will look like, early signs of where things are headed may surface in the coming weeks.

Impacting both the CSRD and CSDDD – the Omnibus Stop-the-clock directive, now EU law, is being transposed into national law by Member States, a process set to finish before the end of 2025. The Omnibus proposed Content directive is being discussed by EU legislators, with adoption in 2025 feasible, although ambitious.

Impacting the CSRD – we expect the EC to adopt in the coming weeks a secondary legislation to simplify the EU Taxonomy and to extend certain transitional reliefs in the European Sustainability Reporting Standards (ESRS) – both due to go through a scrutiny process and planned to be effective for FY25 reporting. We also anticipate the release of exposure drafts with proposed revisions to existing ESRS at the end of July.

Meanwhile, there are other developments apart from the Omnibus. Notably, the CSRD transposition is still ongoing in several Member States. Plus, we continue to await standards for non-EU groups, as well as voluntary standards for SMEs. 

Scroll down to read more about these developments.

Understand EU sustainability reporting

Here you’ll find key information to help you navigate the evolving EU sustainability reporting landscape. Use the jump links below to quickly access specific topics: an overview of the relevant EU sustainability reporting regulations, a timeline of key Omnibus milestones, and details about other developments relating to topics like EU Member State transposition, forthcoming implementation guidance, voluntary standards, and standards for non-EU groups.

Overview of the CSRD, CSDDD and Omnibus

Click on the links to understand more about EU sustainability reporting.

CSRD

CSRD

The CSRD amends the Accounting Directive (2013/34/EU), which applies to non-EU companies that meet certain employee, turnover (revenue) and/or asset thresholds; and to non-EU groups with substantial activity and a presence in the EU. In-scope companies are required to prepare sustainability reporting in accordance with the ESRS.

Directive 2013/34/EU
CSDDD

CSDDD

The CSDDD (2024/1760) applies to non-EU companies that meet certain revenue and/or royalty thresholds. In-scope companies are required to comply with certain due diligence obligations (including reporting and transition plan adoption) related to actual and potential adverse human rights and environmental impacts.

Directive 2024/1760
Omnibus

Omnibus

A package of directives and proposals intended to simplify sustainability reporting and due diligence requirements – including the CSRD and CSDDD – while still achieving the overall ambition of the European Green Deal. With this package, the EC aims to significantly reduce administrative burdens, increase legal clarity, and support businesses in their transition toward sustainable and competitive operations within the EU market.

Omnibus package

Key Omnibus milestones

The EC’s efforts to simplify and streamline certain EU legislation (including the CSRD and CSDDD) are being executed via a series of Omnibus packages and other simplification measures. These measures are being introduced in waves, with different parts progressing at varying speeds. 

To help you stay informed, we’ve created five separate timelines – each tracking a specific piece of the Omnibus package. This approach will give you a clearer view of the distinct regulatory pieces and their unique paths forward.

Click each of the boxes below to view a timeline of what’s happened so far and what’s expected next. As legislative discussions evolve, future dates may shift, so check back regularly for the latest updates.

 

Other developments

Outside the Omnibus, a lot is still happening with the CSRD and CSDDD. Hover over each of the following boxes to read the latest.

CSRD: Transposition

The CSRD entered into force in January 2023. Despite the deadline of July 6, 2024 to transpose it into national law, a handful of Member States have not yet transposed.

For Wave 1 companies, these delayed transpositions continue to cause legal uncertainties relating to, for example, continued application of the sustainability reporting regime under the Non-Financial Reporting Directive (NFRD). In this case, some companies have still applied ESRS, but on a voluntarily basis.

CSRD: Non-EU standards

Non-EU groups in scope of the CSRD are required to report in accordance with the forthcoming non-EU group standards (NESRS). The EC’s adoption deadline for the NESRS is June 30, 2026. An exposure draft was expected for public consultation in early 2025 but was delayed to accommodate work on the Omnibus.

At this point, the exposure draft will likely not be released before EFRAG provides its draft revisions to the EC on the first set of ESRS (see ‘Proposed ESRS simplifications’ timeline above). When the NESRS exposure draft is released, EFRAG may ask for comments on an option to allow non-EU groups to restrict disclosures to cover only those activities that relate to products sold into the EU. This limitation would likely be proposed to apply to all topical standards except ESRS E1 (climate change).

CSRD: Guidance

To support CSRD implementation, EFRAG has developed a Q&A process and issued nonauthoritative guidance on double materiality, value chain and ESRS datapoints. Additional nonauthoritative guidance on other topics will likely not be released before EFRAG provides its draft revisions to the EC on the first set of ESRS (see ‘Proposed ESRS simplifications’ timeline above).

To further support CSRD implementation, the Committee of European Auditing Oversight Bodies (CEAOB) also issued guidelines to support assurance providers in providing limited assurance on sustainability reporting.

CSRD: VSME

In July 2025, the EC is expected to endorse a standard for voluntary application by entities not in the scope of the CSRD (VSME). A draft of the standard was issued by EFRAG to the EC in December 2024.

CSDDD: Transposition

The CSDDD entered into force in July 2024. The Stop-the-clock directive officially extends the transposition deadline to July 26, 2027. To avoid a fragmented regulatory landscape, a harmonization principle allows Member States to introduce into their national law more stringent and/or specific provisions but prohibits diverging from certain due diligence obligations. The proposed Content directive would expand the harmonization principle to further aspects of the due diligence process.

CSDDD: Guidance

By March 31, 2027, the EC will establish the CSDDD report content and criteria, which is expected to align with similar reporting criteria in the CSRD.

The EC will issue guidelines to support companies in fulfilling due diligence obligations in a practical manner. This includes practical guidance on the transition plan by July 26, 2027, and general guidelines by January 26, 2027 (the proposed Content directive would bring forward this date by 6 months to July 26, 2026).

CSDDD: Assessments

By July 26, 2026, the EC will assess the need for additional due diligence requirements for regulated financial undertakings related to the provision of financial services and investment activities. The proposed Content directive would eliminate this assessment.

By July 26, 2030, the EC will assess the effectiveness of certain implementation matters, including whether a scoping approach specific to high-risk sectors should be introduced and whether the value chain definition should be revised.

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Bryce Ehrhardt
Managing Director, Dept. of Professional Practice, KPMG LLP
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Marissa Spencer
Director, Dept. of Professional Practice, KPMG US

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