August 7, 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 making 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’s) proposed Content directive, read our Hot Topics linked below.

For an overview of the latest developments on all the moving parts of EU sustainability reporting, including Omnibus updates, continue scrolling – and regularly check the timelines below for key updates.

Latest: ESRS exposure drafts for public review and update on VSME standard

US companies – here’s what matters most
Since most US companies complying with the CSRD have EU subsidiaries in the second wave of reporting, the Stop-the-clock directive gives them an extra two years to prepare for CSRD reporting. EFRAG’s proposed revisions simplifying ESRS offer some early insight into what their future reporting requirements may look like. However, US companies will have to wait until near the end of the year at the earliest to see the revised CSRD scoping requirements.

The European Financial Reporting Advisory Group (EFRAG) has issued proposed revisions to European Sustainability Reporting Standards (ESRS) for public comment, aiming to reduce the reporting burden for companies. Read our web article, Proposed amendments to simplify ESRS, which includes an in-depth guide that explores the proposals and practical implications. 

Also, the EC has adopted a recommendation on voluntary sustainability reporting for small and medium-sized companies (SMEs), which includes a voluntary standard that is intended to reduce the reporting burden for SMEs that are asked to provide information by companies in scope of the CSRD. Read our web article, VSME: A voluntary sustainability reporting option.

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.

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, proposed by the EC

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).

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.

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).

CSRD: VSME

The EC has adopted a recommendation on voluntary sustainability reporting for SMEs that includes a voluntary standard for SMEs (VSME). The EC is encouraging companies in scope of the CSRD to leverage this standard when making requests to SMEs, to the extent possible.

The EC still plans to adopt a delegated act on a voluntary standard. The timing of this adoption will depend on the progress and outcomes of the ongoing Omnibus proposal negotiations.

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 divergence 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 are 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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