CSRD & Digital Product Passports
EU 2022/2464
The CSRD requires the largest companies to report on environmental and social sustainability using European Sustainability Reporting Standards (ESRS). Since the 2026 Omnibus amendment, only EU companies with more than 1,000 employees and over €450 mi...
Overview
The CSRD requires the largest companies to report on environmental and social sustainability using European Sustainability Reporting Standards (ESRS). Since the 2026 Omnibus amendment, only EU companies with more than 1,000 employees and over €450 million turnover are in scope. Product-level environmental data captured in DPPs feeds directly into CSRD reporting requirements, particularly around carbon footprint, resource use, and circular economy metrics.
Key Requirements
The CSRD introduces several requirements that directly impact how businesses manage product data and Digital Product Passports.
- Detailed sustainability reporting using ESRS standards
- Double materiality assessment (impact and financial)
- Scope 1, 2, and 3 emissions reporting
- Circular economy and resource use disclosures
- Supply chain due diligence reporting
- Third-party assurance of sustainability reports
- Machine-readable digital tagging (once the tagging rules are adopted)
- Product-level environmental data aggregation
Implementation Timeline
Key dates and milestones for the CSRD.
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January 2024
Phase 1: Large Public-Interest Entities
Companies already subject to NFRD begin CSRD reporting for FY2024.
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April 2025
Stop-the-Clock
Reporting for the second and third waves is postponed by two years.
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February 2026
Omnibus I Adopted
Scope narrowed to companies with more than 1,000 employees and over €450 million turnover; listed SMEs removed.
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January 2027
Newly In-Scope Large Companies
Report for financial years starting on or after 1 January 2027, with first reports in 2028.
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January 2028
Non-EU Companies
Non-EU groups with over €450 million EU turnover report for financial years from 2028.
Affected Sectors
These product sectors are impacted by the CSRD. Each has specific DPP requirements and deadlines.
Frequently Asked Questions
How does CSRD connect to DPPs?
DPPs capture product-level sustainability data (carbon footprint, materials, recyclability) that aggregates into the company-level disclosures required by CSRD. Having DPPs makes CSRD reporting significantly easier.
Who needs to comply with CSRD?
Since the 2026 Omnibus amendment: EU companies with more than 1,000 employees and over €450 million turnover, and non-EU groups with over €450 million EU turnover. Listed SMEs are no longer in scope. Reporting phases in from financial year 2024 to 2028.
Is CSRD reporting machine-readable?
It will be. CSRD reports are to be digitally tagged in ESEF/iXBRL format, like the machine-readable data in DPPs, but the 2026 Omnibus postponed tagging until the detailed rules are adopted.
Can DPP data reduce CSRD compliance burden?
Absolutely. Product-level DPP data provides the raw environmental and circularity data needed for CSRD disclosures, reducing manual data collection effort.
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