Who it is for · Mid-sized companies
First the question of whether an obligation exists at all.
In companies without a dedicated sustainability team the topic usually lands in finance or with the management board — alongside everything else. The most expensive variant is to overestimate the scope and collect data nobody asked for.
Under Directive (EU) 2026/470 a CSRD reporting obligation arises only where both thresholds are exceeded: more than 1,000 employees and more than €450 million in net turnover. Many companies that believed themselves in scope no longer are. The demand for supply chain data remains — and for that there is a voluntary standard that bounds the extent.
Typical questions
The questions it starts with.
Are we in scope?
Both thresholds must be exceeded. For most mid-sized companies the answer has read differently since 2026.
From which financial year?
Application is generally foreseen for financial years from 1 January 2027; national transposition has to be checked separately.
What do our customers ask for anyway?
Supply chain requests arrive regardless of obligation. The voluntary standard is the means of holding them to a defined scope.
Which topics are material for us?
A first read from sector and business model — a starting point for the materiality assessment, not a substitute for it.
What does such a report even look like?
Published reports of comparable companies sit in the collection and show extent and language.
What will this cost us internally?
The gap list shows which data have to be collected in the company — the basis for a defensible effort estimate.
Built for this
What is built for a first reporting cycle.
- A scoping test against the applicable thresholds, with citations
- An assessment of what is sensible towards customers and banks even without an obligation
- A first read of material topics from a few details about the business model
- A gap list as the basis for an internal effort estimate
- Report drafts with placeholders instead of invented metrics
- Published reports of comparable companies as a benchmark
The most expensive mistake
It is not reporting too little. It is overestimating the scope: collecting data that neither the law nor the customer asked for, because nobody looked up the requirement.
The revised standards cut mandatory data points by about 61 per cent. Anyone working from the 2023 position is collecting a substantial share of them for no reason.
Frequently asked
How do I find out whether we are in scope?
Both thresholds must be exceeded: more than 1,000 employees on average over the year and more than €450 million in net turnover. If either is below, no obligation arises under Directive (EU) 2026/470. National transposition has to be checked separately — state of transposition.
What if customers still ask for sustainability data?
That is the normal case, obligation or not. A voluntary standard exists for companies up to 1,000 employees. Its practical value is in holding supply chain requests to a defined scope.
Do we need advisers for this?
Often not for the scoping test and a first draft. For the materiality assessment and anything subject to assurance, professional support is sensible. CSRD-GPT moves the line at which external help becomes necessary.