However, EFRAG's move to publish a draft for consultation at the same time as the ESRS at the end of January 2024, which is aimed at SMEs not covered by the CSRD, came as a surprise: With the so-called Voluntary ESRS for Non-Listed Small- and Medium-Sized Enterprises the "VSME ESRS", EFRAG is addressing all those companies that are not covered by the CSRD and thus the aforementioned concretisations (i.e., ESRS and ESRS LSME), but which nevertheless wish to take similar measures.

In their annual financial report, companies will have to disclose sustainability information in the management report. The details of the sustainability information to be published are set out in Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, to which the French Decree 2023-1394

Corporate Sustainability Reporting Directive (CSRD)

Reporting via the CSRD will incorporate the increasing demand for digitization. Companies will be required to prepare their reporting in XHTML format in accordance with the European Single Electronic Format Regulation. They are also required to tag sustainability information within the report according to a digital categorization system, which should be developed with the ESRS.

The CSRD will also mandate the reporting of Scope 3 emissions from across the full value chain. This arises from guidance set out by the European Financial Reporting Advisory Group’s (EFRAG) draft European Sustainability Reporting Standards (ESRS) - specifically “Disclosure Requirement E1-9 – Scope 3 greenhouse gas (GHG) emissions” which states that “The undertaking shall disclose its gross indirect Scope 3 GHG emissions in metric tons of CO2 equivalent.”

2028 for non-EU companies (to be reported on in 2029),

With data for the CSRD needing to be captured as soon as 2024 for EU companies (to be reported on in 2025)