What is CSRD? It's the framework for corporate sustainability reporting.

The CSRD (Corporate Sustainability Reporting Directive) is the European Union's (EU) Directive 2022/2464. As its name suggests, it is a reporting regulation: it obliges companies within its scope to disclose the environmental, social, and governance aspects of their activities to the public in a standardized manner.

Service note: AES Innovation carries out the EU compliance work described on this page (PPWR, digital product passport, CBAM, etc.) in collaboration with expert solution partners; it does not provide these services directly. These activities are outside the scope of our accreditation (EU-0631-M).

The content of the reporting is determined by common standards known as ESRS (European Sustainability Reporting Standards). These standards cover topics such as climate and emissions, energy, water, circularity, employee rights, labor conditions, and business ethics. The aim is to make sustainability information comparable and auditable, just like financial information.

Another fundamental concept of CSRD is the principle of double materiality: the company assesses both the impact of sustainability issues on its own financial situation and the impact of its operations on the environment and society. This text is for informational purposes only and does not constitute legal advice.

  • CSRD = reporting obligation: the company discloses sustainability data in a standard format.
  • Reporting content is determined by ESRS standards.
  • The principle of dual importance: both financial impact and environmental/social impact are assessed.
  • The reports are verified with a limited level of assurance by accredited insurance providers.

The difference between CSRD and CSDDD: reporting and due diligence are separate obligations.

Two regulations that are most often confused are CSRD and CSDDD. The distinction is simple but critical. CSRD is a reporting obligation: it regulates what you measure and what you disclose. CSDDD (Corporate Sustainability Due Diligence Directive), on the other hand, is a due diligence/intent assessment obligation: it regulates what you must do to identify, prevent, and mitigate adverse human rights and environmental impacts in your supply chain.

In short, CSRD stands for 'tell', while CSDDD stands for 'do and correct'. A company can be subject to both; in this case, it must both report sustainability data and implement due diligence processes in its supply chain. The two obligations complement each other but are legally separate, and their scope thresholds are also different.

The details of CSDDD's due diligence processes are beyond the scope of this article; they are covered in a separate, in-depth informational piece. Here, we only aim to clarify the difference between it and CSRD.

  • CSRD: What will you report (reporting/disclosure obligation)?
  • CSDDD: What will you do in the supply chain (duty assessment/duty of care)?
  • These are two separate regulations; their scope thresholds and dates are different.
  • A company can be in both categories; in this case, the obligations run parallel.

Omnibus 2026 simplification: How have the scope thresholds and dates changed?

The simplification process that began in 2025 significantly reshaped the CSRD and CSDDD with the EU's 'Omnibus' package. It's important to distinguish between the two main parts of this package: first, the 'stop-the-clock' regulation that postponed implementation dates, and then the content (essential) regulation that narrowed the scope and content.

The Stop-the-Clock regulation (EU) was published in the Official Gazette as Directive 2025/794 on 16 April 2025, postponing specific implementation dates for reporting and due diligence obligations; the transposition date for member states' domestic law was set as 31 December 2025. The main Omnibus regulation, which narrows the scope thresholds and content, was addressed in a separate process; since the final details and dates of the main regulation may change while this content is being prepared, the following threshold and date information should be confirmed with the current official text.

The most significant change on the CSRD side is the narrowing of the scope: the reporting obligation is largely focused on companies with more than 1,000 employees and a net turnover exceeding €450 million; for non-EU companies, the criterion of a turnover exceeding €450 million generated in the EU has become prominent. Furthermore, it is reported that there has been a significant reduction in the data points of the ESRS standards, and the assurance level of the reports remains at the limited assurance ceiling.

On the CSDDD side, the thresholds have been raised to 5,000 employees and €1.5 billion in turnover, significantly narrowing the scope; the deadline for compliance with due diligence obligations has reportedly been extended to July 26, 2029. Some of these figures and dates will be finalized depending on transposition into national law by member states; details that cannot be verified are subject to change.

  • Stop-the-clock: (EU) 2025/794, Official Gazette 16 April 2025; implementation dates postponed.
  • The main Omnibus amendment, which narrows the scope and content, is a separate process; the details and dates must be confirmed from the current official text.
  • CSRD scope: reportedly focuses on criteria such as having more than 1,000 employees and a turnover exceeding €450 million.
  • Significant reduction in ESRS data points; assurance level at limited assurance ceiling.
  • CSDDD thresholds raised to 5,000 employees / €1.5 billion; compliance deadline postponed to 2029 (subject to change)

Who is now included? What does the postponement not change?

Following the simplification, many medium-sized companies were either directly excluded from CSRD coverage or had their initial reporting dates pushed back. According to publicly available summaries, while large companies that already reported in the first wave are maintaining their obligations, the initial reports for companies that will be included later appear to have been pushed back to 2028 based on fiscal year 2027 data.

However, the postponement does not mean 'the issue is off the agenda'. Reporting continues for large EU companies covered; these companies still need to collect the data required for their own reporting from their supply chains. Therefore, while the threshold changes directly reduce the number of companies obligated, they do not eliminate the data demand.

Whether a company currently falls within the scope of the agreement requires a combined assessment of criteria such as number of employees, turnover, legal form, and links to the EU, as well as member state practices. This assessment requires expertise and cannot be done through this informational document.

  • The first wave of reporting continues with large EU companies.
  • Initial reports for subsequent coverage have been pushed back to 2028 with FY2027 data (confirmation recommended).
  • The scope reduction decreased the number of obligated companies, but it did not end data requests.
  • A definitive scope decision requires the current official text and expert evaluation.

Indirect impact on Turkish suppliers: obligations arising via the supply chain.

Most companies in Türkiye are not directly covered by CSRD. Nevertheless, the impact is real and growing: large EU customers are requesting sustainability data from companies in their supply chains, i.e., Turkish suppliers, in order to prepare their own CSRD reports. This means the obligation is being transferred 'throughout the chain'.

The requested data typically includes carbon emissions (coverage information) by product or facility, energy consumption, water and waste data, and social indicators such as employee rights and safety. The EU buyer consolidates this data in its own report; a supplier who cannot provide the data creates a gap in the buyer's reporting process.

The critical point in this table is that providing sustainability data in a regular, measurable, and documented manner is transforming from a burden into a competitive advantage. A Turkish supplier who keeps their data readily available strengthens their position as the preferred supplier for EU customers; those who cannot may face the risk of losing orders. This information aims to help suppliers assess the situation early.

  • Most Turkish companies are not directly included, but EU customers are requesting data.
  • Required data: emissions, energy, water, waste, labor force, and occupational safety indicators.
  • Failure to provide data creates gaps in the EU recipient's reporting.
  • Providing measurable and verifiable data is a competitive advantage.

How can a Turkish supplier prepare today?

The postponement can be seen as time gained for preparation. The priority is to understand early on which EU customer will request which data and how often, and to establish the internal processes to generate this data. Keeping a record of energy and emissions data, clarifying measurement points, and ensuring data traceability are fundamental steps.

The accuracy of energy data and the safety of the facility's electrical infrastructure are often overlooked aspects of this picture. Periodic inspections of electrical installations are valuable for establishing a reliable foundation for both occupational safety and energy efficiency data. Such inspections are carried out under the supervision of qualified engineers and within the scope of accreditation.

In short, preparation is two-pronged: on the one hand, establishing the measurement and recording discipline that will generate sustainability data, and on the other hand, ensuring that the physical infrastructure (such as electrical installations) on which this data is based is safe and properly inspected. This briefing provides a general roadmap; company-specific steps require a separate assessment.

  • Clarify the EU customer's data expectations early on.
  • Establish a discipline for measuring and recording energy and emissions data.
  • Ensure that the data is traceable and documentable.
  • Electrical installation inspections contribute to workplace safety and energy data reliability.

Information Note

This content is for informational purposes only. AES is not an approved body/certification body; it does not issue sustainability reports or CSRD assurance services; it does not conduct ESRS compliance audits. Sustainability report assurance and ESRS compliance assessment are the responsibility of accredited assurance providers.

AES's TÜRKAK accreditation is only for the scope of 6.1 Electrical Installation inspection. The CSRD, CSDDD, and Omnibus information above is for general purposes only and does not substitute for legal or regulatory advice. Details such as date, threshold, and scope should be confirmed from current official texts and expert opinions; unverified points are subject to change.

  • AES is not a certification/approved body; CSRD does not provide assurance services.
  • ESRS compliance auditing is the job of accredited assurance providers.
  • AES's TÜRKAK accreditation is only for the scope of 6.1 Electrical Installation inspection.
  • This content is for informational purposes only; confirmation with the current official text is recommended.

Related Services and Content

Frequently Asked Questions

What is the main difference between CSRD and CSDDD?

CSRD is a reporting obligation: it regulates the standardized disclosure of a company's sustainability data. CSDDD, on the other hand, is a due diligence/duty obligation: it regulates the identification and mitigation of negative impacts in the supply chain. They are two separate regulations; in short, CSRD means 'tell,' while CSDDD means 'do and correct.'.

Did the omnibus simplification change the scope and dates of the CSRD?

Yes. The simplification process, which began in 2025, narrowed the scope and postponed the deadlines. The 'stop-the-clock' regulation (EU) 2025/794, which postponed the implementation dates, was published on April 16, 2025. The main Omnibus regulation, which narrowed the scope thresholds, was addressed in a separate process; it is reported that the CSRD largely focuses on the criterion of more than 1,000 employees and a turnover exceeding €450 million. The final versions of the thresholds and dates should be confirmed from the current official text.

Is my Turkish company included in the CSRD program?

Most companies in Türkiye are not directly covered by CSRD. Determining the exact situation requires a combined assessment of criteria such as number of employees, turnover, legal form, and connection to the EU. Even if you are not directly covered, your EU client may request data from you. This is an informational note; the coverage decision requires expert assessment.

Why am I affected if I'm not directly within the scope?

Because large EU customers collect data from their supply chains for their CSRD reports. You may be asked to provide data such as emissions, energy, water, and social indicators. This is a transfer of responsibility through the supply chain; being able to provide the data translates into a competitive advantage.

Does AES prepare CSRD reports or provide CSRD assurance services?

No. AES is not a certification body or accredited organization; it does not issue sustainability reports, provide CSRD assurance services, or conduct ESRS conformity audits. These are the responsibilities of accredited assurance providers. AES's TÜRKAK accreditation is only for section 6.1 Electrical Installation inspection.

What is the relationship between electrical installation inspections and sustainability data?

Ensuring the reliability of energy consumption and occupational safety data is closely related to the safety and inspection of the facility infrastructure. Periodic electrical installation inspections, conducted under the supervision of qualified engineers, contribute to the robustness of both occupational safety and energy efficiency data. This information does not present the inspection as a sustainability reporting service.