CSRD: the new sustainability reporting duty for companies

Omnibus Directive I (2026/470), published on 26 February 2026, has changed the rules of the game: roughly 90% of the companies originally required to file sustainability reports under the CSRD are now out of scope (Cuatrecasas, 2026). But if your company has more than 500 employees or turnover above €250 million, the obligation still stands and the clock is already running.

The CSRD (Corporate Sustainability Reporting Directive) is the European directive that requires companies to report on their environmental, social and governance impact with the same rigour they apply to their financial accounts. This is not a voluntary report or an image exercise: it is a legal obligation verified by independent auditors.

What is the CSRD and why does it affect your company?

Directive 2022/2464, approved in December 2022, replaced the earlier Non-Financial Reporting Directive (NFRD) with a clear aim: to make sustainability information as reliable, comparable and auditable as financial information.

The CSRD introduces three fundamental changes to the previous framework:

• Mandatory standards (ESRS): a free-format report is no longer enough. Companies must follow the 12 European Sustainability Reporting Standards published by EFRAG.
• Double materiality: the report must cover both how the company affects its environment and how sustainability risks affect the company.
• Mandatory assurance: an independent external verifier must audit the information, at a level of assurance comparable to that of the annual accounts.

In Spain, the CSRD is being transposed through the Ley de Información Empresarial sobre Sostenibilidad (LIES), the Spanish sustainability reporting act, approved as a bill in October 2024 but still going through parliament. In the meantime, the CNMV has made clear that listed companies must apply the European standards directly.

Which companies must report after the Omnibus Directive?

Omnibus Directive I has raised the thresholds substantially. Only companies that meet at least two of these three criteria over two consecutive financial years are now in scope:

Listed SMEs, which the original CSRD brought in from 2026, are now outside the obligation. They will be able to report voluntarily using simplified standards (VSME).

Subsidiaries and branches in Spain of third-country companies with EU turnover above €150 million also fall in scope, from 2028.

Is my company in scope?

If your company has fewer than 500 employees and turnover below €250 million, you are probably not directly in scope. Two factors are still worth bearing in mind:

• Value chain effect: large companies in scope can require ESG data from their suppliers and subcontractors, even when those are SMEs.
• Access to finance: banks and investors apply increasingly strict ESG filters. Having a sustainability report, even a voluntary one, improves your credit profile.

Not sure whether this affects your company? Our specialist consultancy team can carry out a quick review of your situation.

What the sustainability report must include: the 12 ESRS standards

The European Sustainability Reporting Standards (ESRS) define exactly what information the report must contain. They are grouped into 12 standards:

Cross-cutting (mandatory for every company)

• ESRS 1: General requirements — principles for preparing the report
• ESRS 2: General disclosures — business model, governance, sustainability strategy

Environmental

• ESRS E1: Climate change — Scope 1, 2 and 3 emissions, transition plan
• ESRS E2: Pollution — air, water, soil
• ESRS E3: Water and marine resources
• ESRS E4: Biodiversity and ecosystems
• ESRS E5: Resource use and circular economy

Social

• ESRS S1: Own workforce — working conditions, diversity, health
• ESRS S2: Workers in the value chain
• ESRS S3: Affected communities
• ESRS S4: Consumers and end users

Governance

- ESRS G1: Business conduct — anti-corruption, lobbying, tax practices

Not every topical standard is mandatory for every company: it depends on the outcome of the double materiality analysis. Only ESRS 1 and ESRS 2 are universally mandatory.

Double materiality: the key concept in the CSRD report

Double materiality is the core of the CSRD. It requires each sustainability topic to be analysed from two perspectives:

Impact materiality (inside out): how does your company affect the environment and society? Think of the emissions from your production plant or the working conditions in your supply chain.

Financial materiality (outside in): how do sustainability risks affect your company? Think of how a drought can interrupt your supply chain, or how climate regulation can push up your operating costs.

A topic is "material" if it is relevant from either perspective. The outcome of the analysis determines which topical ESRS standards you must include in your report and which you can leave out.

Application timetable and the state of play in Spain

The original CSRD timetable set out a phased application. Omnibus Directive I has introduced significant changes:

In Spain the picture has one particular feature: transposition has not been completed. The LIES is still going through parliament. In the meantime, the framework in force is Ley 11/2018 on non-financial information, although the CNMV requires listed companies to apply the European standards directly.

Member states have until 19 March 2027 to transpose Omnibus Directive I.

Penalties, audit and assurance

Mandatory assurance

All sustainability information must be verified by an independent auditor or assurance provider, at a limited assurance level that will be raised progressively towards reasonable assurance. In Spain, the ICAC (the Spanish accounting and audit institute) supervises the quality of that work.

Penalty regime

The CSRD leaves the penalty regime to each member state. In Spain, penalties will be set out in the LIES. For reference, France has set fines of up to €18,750 for failing to publish the required sustainability report.

Beyond the fines, non-compliance has immediate practical consequences:

• Exclusion from ESG indices and sustainable investment funds
• Loss of access to finance tied to sustainability criteria
• Reputational damage with clients, investors and talent

Do you need to prepare your sustainability report? Contact our team for an initial review.

How to prepare: from obligation to competitive advantage

The CSRD sustainability report does not have to be only a compliance cost. Companies that get ahead of it gain concrete advantages:

• Access to green finance: banks and ESG funds require verified sustainability data before granting preferential finance.
• Public tenders: public bodies give more and more weight to sustainability criteria in their specifications.
• Attracting talent: professionals favour companies with a verifiable ESG commitment.
• Groundwork for certification: a well-prepared CSRD report makes it far easier to obtain certifications such as B Corp or to measure your carbon footprint.

Action plan in 4 steps

1. Check whether your company is in scope: apply the Omnibus test of 3 criteria (500 employees, €250M turnover, €125M balance sheet)
2. Carry out the double materiality analysis: identify which ESRS topics are relevant to your company
3. Gather data and set up measurement systems: above all GHG emissions (Scope 1, 2 and 3), social data and governance data
4. Engage an assurance auditor: select an accredited independent verifier

At Tecnocim Innova we support companies through the whole process: from the initial review to preparing the report and connecting it with the funding available in Spain for the sustainable transition.

Contact us to plan your CSRD roadmap with no obligation.