CSRD2026
Does youryour company fall within the scope
Non-listed companies falling within the scope of the Corporate Sustainability Reporting Directive (CSRD) must comply with the directive from the 2027 financial year onwards and publish their first sustainability report in 2028. While this may give some breathing space, if you want to use that time wisely, start now.
Does this sound familiar?
CSRD reporting is not a matter of a few months. It is an organisation-wide process that requires preparation in terms of data, governance, processes and strategy, all of which usually takes more time than organisations expect.
Does your company fall under the CSRD?
The Omnibus Package has significantly narrowed the scope of the CSRD. Whilst originally all large companies (i.e. those with more than 250 employees) fell underit, the reporting obligation in Wave 2 now only applies to the largest unlisted companies.
The criteria for the Wave 2 reporting obligation:
- more than 1,000 employees (annual average);
- net turnover of more than €450 million.
If your Wave 2 company meets both criteria, you fall within the scope. Your first official CSRD report will then cover the 2027 financial year and be published in 2028.
In many cases, even companies that fall below the new thresholds will be indirectly affected. Large CSRD-obligated customers or parent companies are increasingly requesting sustainability data from their suppliers; the pressure within the supply chain is very real.
→ Not sure whether your organisation falls within the scope? Request a no-obligation consultation.
CSRD-rapportage is geen verslag dat je in enkele maanden tijd realiseert. Het is een organisatiebreed proces dat voorbereiding vraagt op vlak van data, governance, processen en strategie - en dat vergt meer tijd dan de meeste organisaties verwachten.
whymany companies overestimate their timeline
It’s a common misconception: ‘The deadline is 2028, so we’ve still got plenty of time.’ In reality, anyone who only starts to prepare in 2027 will betoo late. Pantarein advises Wave 2 companies to use the 2025 and 2026 financial years as trial years: the first year to train teams and test systems; the second to carry out a ‘dry run’; a full-scale test reporting exercise for the 2026 financial year, during which the auditor will conduct an informal readiness assessment. As a result, you’ll be well prepared for the official start.
4 reasons that organisations start too late:
1. The double materiality analysis (DMA) takes time
The revised European Sustainability Reporting Standards (ESRS) allow for a simplified DMA. Nevertheless, a robust analysis remains a step-by-step process involving internal validation and audit-proof documentation. In practice, this process can easily take three to four months.
We recommend that companies that already carried out a DMA in 2024 update their analysis in 2026.
2. Data collection is an operational issue, not a reporting one
ESG data is rarely readily available in existing systems. HR, operations, finance, procurement: multiple departments must collaborate, and systems often need to be adapted or expanded.
3. Governance and internal processes must be established
CSRD reporting is not a one-person job. Clear responsibilities, internal control mechanisms and approval procedures are required, with these still lacking in many organisations.
4. Assurance requires a well-prepared organisation
For external verification by an auditor, data must be traceable, substantiated and reproducible. Without thorough preparation, the process will be delayed.
Whatdo you need today?
Wave 2 companies, who must publish their first official report in 2028, should ideally have started their preparations by mid-2025. Those who have not yet begun must set clear priorities today and make the most of the years 2026 and 2027.
These 5 building blocks are worth considering.
1. Double materiality analysis (DMA)
The DMA forms the backbone of your CSRD reporting. It determines which sustainability topics you will report on, and underpins that choice from two perspectives:your company’s impact on people and the environment, and the financial risks and opportunities that sustainability entails.
What you need now:
- a documented, audit-proof methodology in line with the revised ESRS;
- a clear stakeholder process involving internal and external stakeholders;
- prioritisation of material topics per ESRS standard;
- validation by management or the board of directors.
2. Data management
ESRS-compliant reporting assumes that you have the right data, and thatthis data is reliable, traceable and reproducible. For most organisations, thisproves to be a bigger challenge than expected.
What you need now:
- an inventory of the required data points for each material ESRS topic;
- a structured KPI framework;
- clarity on what data is available and its quality;
- a plan to collect missing data or adapt systems;
- internal agreements on data management, responsibilities and validation.
3. Governance
CSRD reporting is a strategic topic. Governance determines how sustainability is embedded in your organisation’s decision-making.
What you need now:
- an owner or steering group for the CSRD process;
- management involvement in decisions regarding materiality and report content;
- internal control mechanisms and approval processes;
- alignment between sustainability, finance, HR and operations.
4. Reporting processes
You don’t simply rattle off a CSRD report at the end of the year. The underlying processes – data collection, internal review, preparation for the assurance engagement – ideally run throughout the entire year.
What you need now:
- an annual calendar with data collection rounds and internal deadlines;
- process descriptions for each ESRS theme: who provides what, when and via which system;
- internal review rounds prior to external assurance;
- agreements on editing, layout and publication of the sustainability report.
5. EU taxonomy
The EU taxonomy is also relevant to some companies. It determines to what extent your activities can be classified as ‘sustainable’, with direct implications for your access to green finance and investor perception.
What you need now:
- a screening of economic activities covered by the taxonomy;
- an initial eligibility/alignment assessment;
- insight into the required technical screening criteria (TSC) and do no significant harm (DNSH) assessments;
coordination with finance regarding integration into annual KPI reporting.
Rapportering en assurance
A CSRD report is subject to mandatory limited assurance. This involves an external auditor – in Belgium, a statutory auditor or a certified accountant –examining, on the basis of sample checks and interviews, whether the report has been prepared in accordance with the ESRS. Assurance requires that data be traceable, consistent and methodologically sound.
What ‘assurance ready’ means in practice:
- data istraceable back to source level;
- internal control mechanisms are demonstrable;
- methods and assumptions are consistent and thoroughly documented;
- The management team has formally approved the content.
Organisations that start their preparations today build up their audit readiness step by step, thus avoiding the time pressure of a last-minute assurance process.
CSRD-rapportering is geen werk van enkele maanden. Het is een organisatiebreed traject dat voorbereiding vraagt op het vlak van data, governance, processen en strategie –en dat kost doorgaans meer tijd dan organisaties verwachten.
Would you like to know where your organisation stands today in its preparations for the CSRD?
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During our free targeted readiness scan, we analyse:
Following the scan, you will receive a clear priority matrix, tailored to your organisation’s context, with concrete recommendations on how to make the most of the remaining time.
CSRD-rapportage is geen verslag dat je in enkele maanden tijd realiseert. Het is een organisatiebreed proces dat voorbereiding vraagt op vlak van data, governance, processen en strategie - en dat vergt meer tijd dan de meeste organisaties verwachten.
