Legislation and regulation
2024 12 12
•
4 MIN
Carolina Skarupa
Product Carbon Footprint Analyst
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The CSRD and the ESRS are almost always mentioned together, but they are not the same thing. In a sentence: the CSRD is the law that requires sustainability reporting, and the ESRS are the technical standards that say exactly what to report and how. The CSRD sets the obligation; the ESRS provide the format. In this article we look at their differences, their similarities and how they stand after the 2025-2026 Omnibus package.
The Corporate Sustainability Reporting Directive (CSRD) is the European rule that sets the framework for sustainability reporting by companies. It replaced and expanded the old Non-Financial Reporting Directive (NFRD). Its aim is to improve the transparency and comparability of ESG information, giving investors and stakeholders a fuller view of how companies perform.
Its central element is double materiality, which requires companies to analyse two perspectives:
The CSRD also requires the sustainability report to be verified by an independent third party (currently with limited assurance), which adds reliability to the information.
The European Sustainability Reporting Standards (ESRS) are the set of standards that define what information a report under the CSRD must contain. The first package, adopted as Delegated Regulation (EU) 2023/2772, includes 12 standards organised into four blocks:
By applying the ESRS, companies produce more complete and comparable reports. They are also connected to the EU Taxonomy, which helps channel investment towards sustainable activities.
| Aspect | CSRD | ESRS |
|---|---|---|
| What it is | A directive (European law) | A set of technical standards |
| Function | Sets the obligation to report and who it applies to | Defines what is reported and how |
| Legal form | Directive (EU) 2022/2464, transposed by each Member State | Delegated Regulation (EU) 2023/2772 |
| Nature | The "what is required" | The "how it is done" |
| Guiding principle | Double materiality | Operationalises double materiality into concrete datapoints |
In short: you cannot comply with the CSRD without the ESRS, and the ESRS would not be mandatory without the CSRD that underpins them.
This is the point that has changed the most. The original CSRD was going to reach around 50,000 companies. The Omnibus package cut that scope drastically. As of 2026, with Directive (EU) 2026/470 already in force (since 18 March 2026):
Companies with subsidiaries or activity in the EU may still be affected, and the cascade effect on suppliers remains. We develop this in our article on the CSRD for SMEs and the supply chain.
The CSRD requires reporting on sustainability-related risks, opportunities and impacts, on the basis of double materiality and with external verification. The ESRS spell out those requirements standard by standard. This is the full set:
Cross-cutting standards:
Environmental standards:
Social standards:
Governance standard:
It is worth bearing in mind that this set is under revision: in December 2025, EFRAG delivered simplified ESRS that notably reduce the number of mandatory datapoints, and the Commission is expected to adopt them as a delegated act around mid-2026. We explain it in our article on the changes to the ESRS and the Quick Fix.
The CSRD is the directive that requires reporting and defines who it applies to; the ESRS are the technical standards that detail what information to include and how. The CSRD is the legal framework, the ESRS are the instruction manual.
Yes, for companies subject to the CSRD. Their mandatory status derives precisely from the CSRD; on their own they would not bind anyone.
Yes. The Omnibus raised the thresholds (more than 1,000 employees and 450 million in turnover), pushed back the deadlines and is behind the simplification of the ESRS. Double materiality, on the other hand, remains the backbone of the system.
The ESRS include data aligned with the EU Taxonomy, so that the information reported helps identify which activities are environmentally sustainable for investment purposes.
If your company needs to prepare its report under the CSRD and the ESRS, at Manglai we help you structure the data and comply with the CSRD in a traceable and auditable way.
Carolina Skarupa
Product Carbon Footprint Analyst
About the author
Graduated in Industrial Engineering and Management from the Karlsruhe Institute of Technology, with a master’s degree in Environmental Management and Conservation from the University of Cádiz. I'm a Product Carbon Footprint Analyst at Manglai, advising clients on measuring their carbon footprint. I specialize in developing programs aimed at the Sustainable Development Goals for companies. My commitment to environmental preservation is key to the implementation of action plans within the corporate sector.
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