Recently, there has been a growing focus on sustainability and corporate accountability, driving substantial changes in reporting obligations for companies within the European Union. The introduction of the コーポレート・サステナビリティ・レポーティング指令（CSRD） represents a major advancement, as it supersedes the earlier 非財務報告指令（NFRD）. This shift marks a critical development, broadening both the scope and the depth of sustainability disclosures.

In this blog post, we will explore the impact of CSRD data points on disclosure requirements and how this directive will shape the landscape of sustainability reporting.

CSRD Overview

The Corporate Sustainability Reporting Directive (CSRD) is an EU legislative framework aimed at improving the transparency and consistency of sustainability reporting. It replaces the Non-Financial Reporting Directive (NFRD) and requires companies to disclose their environmental, social, and governance (ESG) impacts. The CSRD aims to provide stakeholders with reliable sustainability information, ensuring comparability across EU markets and promoting corporate transparency.

When Does CSRD Take Effect?

The CSRD came into force on January 5, 2023 [1], with companies required to apply the new rules for the 2024 financial year, publishing their reports in 2025. This gives organizations time to prepare for the enhanced requirements.

Who Does CSRD Apply to?

Below are the organizations which are affected by the changes:

• Large companies with more than 500 employees, turnover over EUR 40 million, or balance sheet total over EUR 20 million.

• Small and medium-sized enterprises (SMEs) listed on EU markets, excluding micro-enterprises.

• Non-EU entities with over EUR 150 million in EU turnover.

• Financial institutions, including banks and insurance companies, regardless of size.

Understanding CSRD Data Points

CSRD data points refer to specific metrics and indicators that companies are mandated to report under the Corporate Sustainability Reporting Directive. These data points cover a wide range of sustainability issues, including environmental, social, and governance (ESG) criteria, and are designed to ensure comprehensive and comparable disclosure of a company’s ESG performance and impacts.

The CSRD offers an expansive range of 82 disclosures and 1,144 data points for disclosure needs. Organization are not required to cover all of them. There are some obligatory disclosures, but the additional data points and disclosures are just needed if they emerge during the materiality or 二重の重要性 phase.

These data points are defined by sector-specific standards under the 欧州サステナビリティ報告基準（ESRS）, which are aligned with globally recognized frameworks such as the グローバル・リポーティング・イニシアティブ（GRI） そして 気候関連財務情報開示タスクフォース（TCFD）. The CSRD ensures that the data points companies report are comparable across industries, improving the quality and usefulness of sustainability disclosures.

Double Materiality: The Key to Data Collection

The CSRD introduces the concept of double materiality, which is central to its approach to data collection. Under double materiality, companies must consider two types of material impacts:

1. Inside-Out Perspective: How a company’s operations impact environmental and social factors. This includes effects on climate change, natural resources, ecosystems, and communities.
2. Outside-In Perspective: How environmental and social changes, such as global warming or labor shortages, could impact the company’s financial performance, reputation, and long-term viability.

This dual perspective requires companies to gather extensive data across various sustainability factors, ensuring that both their impact on the world and the risks they face from sustainability challenges are properly reported. This broader view differentiates the CSRD from earlier reporting standards and increases the volume and complexity of the data required.

Impact of CSRD Data Points on Disclosure Requirements

The introduction of CSRD data points significantly expands disclosure requirements for companies by mandating detailed reporting on ESG metrics. These data points require businesses to disclose information on various aspects like carbon emissions, resource usage, human rights practices, and corporate governance. With the double materiality concept at its core, companies must not only report their impacts on the environment and society but also assess how sustainability risks affect their financial health.

The increased depth and specificity of CSRD data points elevate the complexity of disclosures, requiring companies to gather and present data in a more comprehensive manner than ever before. This is compounded by the requirement for sector-specific reporting, meaning companies must tailor their disclosures to industry-relevant sustainability concerns. For example, energy companies might focus heavily on emissions and renewable energy initiatives, while manufacturers could highlight waste management and resource efficiency.

について digital format of these reports, in line with the European Single Electronic Format (ESEF) [2], also enhances transparency and comparability of data across sectors. These digital disclosures must be machine-readable, allowing stakeholders to easily access and assess the data, thereby promoting more informed decision-making by investors, regulators, and consumers.

Ultimately, CSRD data points reshape corporate disclosure requirements, pushing companies toward more transparent, accountable, and detailed reporting on sustainability performance. However, compliance also poses challenges, as companies need to adapt their data management systems and ensure accuracy, consistency, and relevance in their disclosures.

Challenges of Complying with CSRD Data Points

Complying with CSRD data points presents several challenges for companies. These include:

• Data Collection Complexity: Gathering comprehensive data across various ESG metrics requires significant time and resources, especially for companies new to sustainability reporting.

• Technology Integration: Implementing systems to collect, manage, and report on the required data in real-time can be costly and complex.

• Accuracy and Consistency: Ensuring data accuracy across multiple reporting units and regions can be difficult, especially for large multinational organizations.

• Sector-Specific Reporting: Tailoring reports to meet industry-specific standards adds an additional layer of complexity.

• 二重の重要性評価: Assessing both a company’s impact on the environment and how environmental risks impact the company requires advanced risk management and forecasting tools.

• Digital Reporting Requirements: Meeting the requirement for digitally formatted, machine-readable reports necessitates updates to IT infrastructure and familiarity with the ESEF.

Preparing for CSRD Compliance

To prepare for CSRD compliance, companies should begin by conducting a comprehensive assessment of their current reporting practices. A gap analysis will help identify which data points are missing and where improvements in data collection and reporting are needed. Furthermore, companies must ensure that their data collection systems are capable of gathering accurate, real-time information across the entire organization.

Investing in technology to automate data collection, analysis, and reporting will be crucial for large firms. Companies should also prioritize integrating sustainability into their core business strategy, ensuring that ESG considerations are not just seen as compliance requirements but as central elements of long-term value creation.

結論

In conclusion, the CSRD represents a pivotal shift in how companies approach sustainability reporting, driving them toward greater transparency and accountability. While compliance may pose challenges, particularly regarding data management and technological integration, it also offers companies an opportunity to enhance their sustainability practices and demonstrate their commitment to environmental and social responsibility. By proactively embracing these new standards, businesses not only adhere to regulatory demands but also position themselves for sustainable growth and competitiveness in an evolving global market.

参考文献:

[1] https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en

[2] https://www.esma.europa.eu/issuer-disclosure/electronic-reporting