11 October 2024
The CSRD will drastically expand companies' obligations to report on environmental, social and governance factors. Under the CSRD, companies will have to describe much more 'qualitatively' their environmental impact, the associated financial risks and their plans to mitigate this impact.
Marloes Brans, Ronnie Bloemberg and Felix Kelder published an article for the European Energy and Environmental Law Review. They provide an overview of the disclosure requirements under the ‘E’ in the CSRD, focusing on the requirements to report on greenhouse gasses and pollution, which – unlike climate change – have gone largely undiscussed to date. They compare those requirements with the existing obligations under European and Dutch environmental law. They show that existing rules generally carry obligations to report raw data and emission details, whereas the CSRD will require companies to provide more context for that information and a more extensive explanation of the risks. The CSRD will also require companies to explain what policies and targets they have defined to reduce their emissions and/or their use of pollutants in the future. They do this by listing the disclosure requirements under the CSRD, using the European Sustainability Reporting Standards (ESRS) adopted by the European Commission on 31 July 2023.