What Is CSRD? The EU's Revised Thresholds and Reporting Timeline

Updated on October 6, 2026. This update covers the simplified CSRD thresholds, the timing of both amendments, and limited assurance requirements.

What Is CSRD, and Why Are Companies Paying Attention?

The Corporate Sustainability Reporting Directive (CSRD) is legislation proposed by the EU in 2021 to replace the Non-Financial Reporting Directive (NFRD). It imposes stricter requirements for companies to disclose comprehensive environmental, social and governance (ESG) data, improving transparency and credibility.

1. Scope after simplification: The threshold for EU companies is now an annual average of more than 1,000 employees and annual net turnover exceeding EUR 450 million; groups must assess eligibility on a consolidated basis. Supply chain data requests and direct CSRD obligations are distinct issues.
2. Third-party assurance requirements: Limited assurance remains the approach. Directive (EU) 2026/470 removed the planned requirement to develop reasonable assurance standards and moved the deadline for adopting limited assurance standards to July 1, 2027. This is the EU's deadline for setting standards, not a company's first assurance date.
3. Growing international impact: The directive affects both EU companies and international suppliers doing business with them.

Companies that cannot adapt quickly may face reputational damage and the risk of losing market access.

Two CSRD Amendments: Delayed Implementation and a Narrower Scope

First amendment: delayed implementation. Directive (EU) 2025/794 took effect in April 2025, postponing the second wave to financial year 2027, with reports published in 2028; the third wave was then postponed to financial year 2028. These were the historical arrangements under the postponement directive. Actual applicability must be reassessed under the subsequent simplification directive.

Second amendment: Omnibus I. Directive (EU) 2026/470 was published on February 26, 2026 and entered into force on March 18. Member States must transpose its CSRD amendments into national law by March 19, 2027. The threshold for EU companies is now an annual average of more than 1,000 employees and annual net turnover exceeding EUR 450 million. Non-EU companies must have generated net turnover in the EU exceeding EUR 450 million in each of the last two consecutive financial years and have an EU subsidiary with net turnover exceeding EUR 200 million in the preceding financial year. Where no such subsidiary exists, applicability is assessed separately against the conditions for an EU branch exceeding EUR 200 million.

2026/470 removed the original third-wave provisions for listed SMEs. Companies should confirm their obligations against the final thresholds and the transposition rules of the relevant Member State, rather than using the old four-wave list to conclude that all listed SMEs must report.

The figure below retains the historical four-phase illustration of the original system. Reporting decisions should be based on the two amendments above and the official legal text.

Official legal texts: Directive (EU) 2025/794, Directive (EU) 2026/470.

What Does CSRD Require?

CSRD requirements are based on the European Sustainability Reporting Standards (ESRS) and cover three main areas:

These requirements aim to improve corporate transparency and accountability in sustainability. Companies need to consider their environmental and social impacts comprehensively and disclose relevant information to encourage more sustainable business practices.

Key Challenges for Companies

With the EU's CSRD requirements now in effect, Taiwanese companies in supply chains also face requests from EU customers for data that meets the standards. Companies therefore face the twin challenges of inefficient data integration and growing supply chain management pressure:

Challenge 1: Difficult Integration and Fragmented, Incomplete Data

Many companies currently hold ESG data across different departments without a unified management approach. For example, the environmental department manages carbon emissions data, while procurement holds supplier data.

This fragmented approach creates the following problems when companies face CSRD's demanding disclosure requirements:

1. Difficult consolidation: Companies spend substantial time searching for data across departments and compiling it using traditional methods. This increases human error and undermines data credibility and accuracy.
2. Repeated data submissions: Without a unified data management mechanism, the same data may be requested repeatedly from responsible internal teams, increasing workloads and reducing internal efficiency.

Challenge 2: Growing Supplier Management Requirements

Large companies subject to CSRD may obtain data from suppliers to prepare their reports, creating data integration needs for Taiwanese SMEs in their supply chains. This does not automatically make all suppliers directly subject to CSRD reporting. Examples include:

1. Greater data accuracy: Suppliers must provide detailed carbon emissions data, material sourcing information and other information, or risk being viewed as non-compliant partners.
2. Additional review requirements: Every link in the supply chain may be asked to submit supplementary data, adding to suppliers' workloads.

If companies in a supply chain cannot provide data that meets requirements, they may jeopardise relationships with key customers and even be forced out of certain markets.

How Should Companies Prepare after CSRD Simplification?

Approach 1: Improve Internal Data Integration

1. Standardise data formats and management rules:
   Use consistent ESG data templates and rules so data from different departments has a uniform format, is easy to integrate, and avoids discrepancies caused by differing formats.
2. Establish a multi-level review process integrated with internal controls

• Collection stage: Departments perform initial accuracy checks to ensure submitted data meets company standards.
• Disclosure stage: Conduct an internal control audit before disclosure to check compliance with CSRD requirements and reduce the risk of rejection.

Approach 2: Improve Supply Chain Transparency

1. Refer to international standards:
   Organise data according to international standards such as GRI and ESRS to strengthen its credibility.
2. Participate in supply chain training:
   Actively participate in CSRD data training offered by large companies to their supply chain partners, improving internal understanding of the requirements and the ability to implement them.

Approach 3: Adopt Digital Tools to Improve Efficiency and Transparency

Digital systems can address the data management challenges companies face in CSRD compliance and deliver the following benefits:

1. Improve data accuracy: Record the history of data changes to ensure more consistent and reliable quality across all submissions.
2. Accelerate data integration: Manage fragmented information centrally to shorten report preparation time.
3. Reduce staff workloads: Automate project management processes to reduce repetitive work and let teams focus on sustainability strategy.

A Sustainability Management Platform in Practice

Sustaihub Syber Sustainability Management Platform offers three key features that help companies ensure the accuracy of sustainability information:

1. Change histories, review workflows and multi-level access controls: Improve data reliability
2. Cross-department data consolidation to resolve fragmented information: Accelerate data integration
3. Automated project management and AI collaboration: Reduce staff workloads

The Syber Sustainability Management Platform helps companies achieve compliance and improve internal efficiency without consuming excessive staff time. With comprehensive support for sustainability, it is an ideal collaboration platform for corporate sustainability reporting.

CSRD ESG Regulations Sustainability Regulations