What are the minimum requirements for CSRD compliance

The Corporate Sustainability Reporting Directive (CSRD), which came into force on January 5, 2023, marked a significant change in European sustainability reporting rules. However, in 2024, the European Commission proposed a revision through the “Omnibus” package, which also includes the so-called “Stop the Clock” mechanism. The latter, already approved, provides for a postponement of the obligation to apply the ESRS standards for certain categories of companies, such as listed SMEs and non-EU companies. Currently, the exact criteria to define the obliged subjects remain under discussion and have not yet been officially modified. Although the aim is to lighten the regulatory burden, companies are still called upon to equip themselves with ESG monitoring tools in line with market and stakeholder expectations.

The Omnibus package introduces a mechanism of postponement of deadlines (“stop-the-clock”), granting more time for companies to comply. Large public interest enterprises with over 500 employees remain subject to the CSRD starting from 2025 (for the 2024 fiscal year). However, other large enterprises (Wave 2) will have to report on 2027 data with publication in 2028, while listed SMEs (Wave 3) will come into effect with 2028 data, published in 2029. Member States will have to transpose the new deadlines by December 31, 2025. These shifts provide a useful margin to organize, update information systems, and start internal training paths.

The CSRD introduces the principle of double materiality for companies, which requires assessing both the impact of business activities on the environment and society and the effects of ESG factors on economic-financial performance. The reports must be prepared according to the European Sustainability Reporting Standards (ESRS), currently in force in their general version. However, a revision process is underway: as agreed by the EU Council on June 23, 2025, the Commission has requested EFRAG to simplify the ESRS by October 31, 2025. The proposals include the possibility of eliminating or postponing sectoral standards and reducing mandatory data points, aiming to facilitate adoption by companies and limit administrative burdens, especially for SMEs. For value chain data, gradual approaches and simplified tools are also considered, but these are still proposals under negotiation.

Compliance with CSRD does not end with reporting; it requires a structural change in business strategy and governance. Companies must define an integrated ESG plan, with clear responsibilities, measurable objectives, and monitoring processes. It is necessary to establish a reliable, possibly automated data collection system and ensure the quality and consistency of the information disseminated. Reporting should be considered a strategic driver that allows, in addition to complying with regulations, reducing reputational risks, improving access to capital, and meeting the expectations of customers and stakeholders.

This article was created as part of the "Biodiversity services EU expansion" project (CUP: E43D22000480009) under the call of Regione Lombardia "PR FESR 2021-2027 – LINEA INTERNAZIONALIZZAZIONE 21-27", aimed at supporting the internationalization of Italian companies. 3Bee is the naturetech company that develops innovative technologies for biodiversity monitoring, protection, and regeneration, supporting companies in defining customized climate strategies based on the analysis of their impacts and dependencies on nature. With a consolidated portfolio in Italy, Germany, and France and significant partnerships, 3Bee continues its expansion into international markets to create a concrete impact through technology