CSRD reporting for UK and other non-EU companies
Businesses outside the EU, beware: you may still be obligated to report per this EU legislation
The Corporate Sustainability Reporting Directive (CSRD) sets new standards for sustainability reporting in the EU – but its impact extends beyond the Union’s borders.
Here’s what UK and other non-EU companies need to know about CSRD reporting.
What is CSRD?
The Corporate Sustainability Reporting Directive (CSRD) is an EU legislation that requires around 50,000 companies to report on how they impact the environment and society. It replaces an older legislation, the Non-Financial Reporting Directive (NFRD), by introducing more detailed reporting requirements and expanding the number of companies that need to comply.
The goal of the CSRD is to make it easier to compare companies’ environmental efforts, as well as to encourage businesses to be more sustainable as part of the EU’s larger effort to reach net zero.
CSRD, explained
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CSRD reporting for UK and non-EU companies
Even though the CSRD is an EU legislation, companies based outside of the Union will need to comply if they fall into one of three categories: if they have securities listed on a regulated market in the EU, if they do significant business in the EU, and/or if they were previously in scope of the Non-Financial Reporting Directive (NFRD).
Category 1: UK and non-EU companies with securities listed on a regulated market in the EU
For companies in this category, CSRD compliance is required if the company – or any of its their subsidiaries – meet two or more of the following criteria:
- €900,000 or more in net turnover
- €450,000 or more in assets
- 10 or more employees
Category 2: UK and non-EU companies that do significant business in the EU
Companies fall under the CSRD’s reporting mandate if they:
- Have an annual EU revenue exceeding €150 million in each of the last two consecutive financial years
- Have an EU branch that generates a net turnover exceeding €40 million
- Have an EU subsidiary that meets two or more of the following criteria:
- €40 million or more in net turnover
- €20 million or more in assets
- 250 or more employees
Category 3: UK and non-EU companies that were previously in scope of the NFRD
Companies in this category include:
- Public Interest Entities (listed companies, banks, or insurance companies) with more than 500 employees at group level
- Public Interest Entities with more than 500 employees and:
- €50 million in net turnover
- €25 million in assets
Learn your reporting requirements with the Legislation Tracker
Answer five simple questions to determine the mandatory reporting requirements, voluntary frameworks, and industry-specific guidelines that apply to your business.
When should UK and non-EU companies report for CSRD?
The implementation timeline for UK and non-EU companies will roll year-by-year out until 2029:
- 2025: companies previously subject to the NFRD, as well as large non-EU listed companies with more than 500 employees, will report on FY 2024.
- 2026: other large companies, including other large non-EU listed companies, will report on FY 2025.
- 2027: UK and non-EU companies that generated a net turnover of more than €1.5 billion in the EU in the last financial year will report on FY 2026.
- 2028: UK and non-EU companies that generated a net turnover of more than €900 million in the EU in the last financial year will report on FY 2027.
- 2029: UK and non-EU companies that generated a net turnover of more than €450 million in the EU in the last financial year will report on FY 2028.
How to prepare for CSRD reporting
Preparing for CSRD compliance can be a challenging process, and the specifics will look different for every business. However, there’s a general six-step process you can follow to set your business up for compliant CSRD reporting:
- Discovery: Determine your specific disclosure requirements and build the functional capacity to complete them. This may involve identifying an internal stakeholder responsible for CSRD compliance and considering organizational tools for managing communications and data storage.
- Materiality analysis: Conduct a double materiality assessment to identify which sustainability topics are most relevant to your business. This involves analyzing both your company’s impact on the environment and society, and how environmental and social factors affect your financial performance.
- Assign responsibility: Identify stakeholders from various departments who will have the necessary data and map out roles and responsibilities for the reporting process.
- Data collection: Gather the required data points from across your organization. This may involve collecting financial transactions, activity data, and supplier-specific information.
- Generate disclosures: Process the collected data, complete necessary calculations, and prepare your report in line with CSRD requirements.
- Use the insights gained: The reporting process highlights potential sustainability improvements in your business operations. Use these to achieve risk mitigation, competitive advantages, and potential cost savings through operational efficiencies.
This six-step outline was adapted from Normative’s handbook to the CSRD: Decoding CSRD. Download the full handbook for a comprehensive – yet easy-to-follow – guide to CSRD compliance, as well as straightforward descriptions of the legislation’s requirements.
Decoding CSRD
Download our user-friendly handbook to break down CSRD compliance into simple explanations and scalable processes.
Download the handbook
Normative can help your business prepare for CSRD
Finding the right partner will be vital to your CSRD reporting work. Normative offers a comprehensive solution to simplify CSRD compliance and maximize its impact on your business:
- Streamlined submission: Our centralized platform simplifies data collection across your organization, guiding you through a step-by-step process for effective cross-departmental reporting. Normative’s scientific and transparent methodology ensures a full audit trail from source to report.
- Expert guidance: We provide practical partnership from the beginning of CSRD to the final report, with expertise tailored to your business and industry. Our strategic support empowers your team, engages stakeholders, and aligns on compliance.
- From reporting to reduction: Turn data into action with detailed footprints for scopes 1, 2, and 3, and built-in reduction planning. Connect the dots between environmental data, supplier engagement, and your ESG targets to find your competitive edge.
By partnering with Normative, you can not only achieve CSRD compliance but also gain complete visibility of your environmental metrics and a competitive advantage in the market.
Book a demo to learn how Normative can help your business with CSRD reporting
FAQs
Frequently asked questions about CSRD reporting for UK and other non-EU companies.
Yes, the CSRD applies to non-EU companies that do significant business in the EU. Specifically, it applies to companies that generated €150 million or more in net turnover in the EU in each of the last two consecutive financial years, and own a large EU-based business, an EU-based subsidiary with listed securities, or an EU branch with substantial turnover.
Yes, UK-based companies are subject to the CSRD if they meet the same criteria as other non-EU companies. This includes generating significant turnover in the EU and having a substantial presence through a subsidiary, branch, or listed securities.
The timeline for non-EU companies to start reporting under CSRD is phased in between 2027 and 2029:
- By July 2027 for companies with over €1.5 billion EU turnover
- By July 2028 for companies with over €900 million EU turnover
- By July 2029 for companies with over €450 million EU turnover
Non-compliance with CSRD can result in financial penalties, reputational damage, and potential exclusion from public tenders and contracts. It may also impact investor relations and access to capital.
CSRD reporting will hold unique challenges to every business, but there is a general six-step process companies can follow:
- Discovery: Determine your specific disclosure requirements and build the capacity to complete them.
- Materiality analysis: Conduct a double materiality assessment to identify relevant sustainability topics.
- Assign responsibility: Identify stakeholders and map out roles for the reporting process.
- Data collection: Gather required data points from across your organization.
- Generate disclosures: Process the data, complete calculations, and prepare your report.
- Ongoing management: Use insights from reporting to drive sustainability improvements.
Consider partnering with sustainability reporting experts to guide you through this process and ensure compliance.
Both the EU’s CSRD and the UK’s SECR (Streamlined Energy and Carbon Reporting) are sustainability reporting frameworks that aim to increase corporate transparency on environmental impacts.
However, they differ in scope. The CSRD is relatively broad, requiring reporting on a wide range of environmental, social, and governance (ESG) topics. In contrast, SECR is more narrowly focused on energy use and carbon emissions.
Companies operating in both the EU and the UK may need to comply with both frameworks.
