🪴 Maixnor WU

CSRD

Nov 04, 20252 min read

General

  • not yet implemented in Austria, deadline 6.7.2024 (already passed)

  • replaces the NFRD in essence

    • NFRD still mandatory for large companies

  • applies within EU

    • applies to all subsidiaries, even if not in EU
    • parent companies which are not in EU are exempted

  • transposition: NaBeG

  • how to look up which member states have implemented a directive

    • eur-lex.europa.eu
    • under national transposition there is a list of implemetations

Reporting Changes

  • uniform EU-Standards ESRS

    • directive needs to be implemented into domestic laws

  • increases requirements for disclosure

    • now part of Management Report
    • must be in digital and in machine readable format

  • have to comply in contrast to NFRD

    • no explanations anymore, qualitative/quantitative data

  • environment, social, governance covered

  • concept of Double Materiality

Assurance

  • mandatory limited assurance (later reasonable) by a statutory auditor or an independent assurance services proveder (IASP)
    • once reasonable assurance kicks in the pressure will increase
      • mostly about auditing firms, they cannot yet provide this service
      • liabilities are too high
    • check for completeness, rather than correctness
    • a huge business in auditing companies
      • no separate departments currently
      • EY Austria acquired sustainability reporting auditing firms, others in the The Big 4 do the same

Topics

  • qualitative and quantitave information
  • environment
  • social
  • governance
    • role & composition of board/management
    • ethics (bribery/corruption and corp. culture)
    • political engagements
    • business relatioships
    • control & risk
    • management

Scope

  • impacts 50.000 firms in EU
  • large firms, listed firms, certain non-EU firms need issue sustainability reports
    • PIEs companies (NaDiVeG companies)
      • large … more like middle size (also non-listed companies) (25 mil assets, 50 mil revenue, 250+ employees)
        • larger scope than NFRD
      • all listed companies
  • includes all subisidiaries
    • even if subsidiary not in EU

Temporal Scope

Sanctions/Further Deadlines

  • possibility of high sanctions
    • since alignment with financial reporting sanctions (which are very strict)
  • Case A - implementation before 1.1.2025
    • in full accordance with ESRS
  • Case B - implementation before 30.4.2025
    • ESRS is mandatory, EU still happy
  • Case C - implementation after 30.4.2025

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