How to define organisational boundaries for CSRD compliance
The CSRD aims to elevate and standardise sustainability disclosures for companies both within and outside the EU that operate across Europe.
According to Greenomy, this directive expands the scope beyond the former Non-Financial Reporting Directive (NFRD) and introduces stringent compliance requirements governed by the European Sustainability Reporting Standards (ESRS). These standards require detailed reporting across a wide array of environmental, social, and governance (ESG) topics.
Before diving into what data to disclose, companies must first determine their organisational boundaries. This is crucial because it clarifies which entities and locations are included under the directive’s scope. Establishing these boundaries is the foundational step that precedes the Double Materiality Assessment (DMA), guiding organisations in comprehensively and accurately assessing their sustainability impacts.
Determining which entities to include in the consolidated CSRD report typically aligns with those included in financial statements, as per ESRS 1, paragraph 62. This alignment ensures consistency across financial and sustainability reports. Even if certain subsidiaries are not material for financial consolidation, they might still be significant for sustainability topics, thereby necessitating their inclusion in the CSRD reports to capture comprehensive sustainability impacts and risks.
Moreover, entities under operational control of the company are required to be included in the CSRD report for certain specific data points, such as Scope 1 and Scope 2 greenhouse gas (GHG) emissions, and pollutants. Operational control plays a significant role in determining the extent of environmental impact an organisation must report, ensuring that all controlled entities, including joint ventures and investees not fully consolidated financially, are accounted for in terms of their environmental impact.
On the other hand, associates or joint ventures not under operational control but part of the company’s value chain (as suppliers or part of business relationships) should also be included in the sustainability disclosures. These entities are accounted for based on their impact connected with the company’s products and services rather than their equity share.
In terms of joint operations, they are treated as part of the financial perimeter of the company under the ESRS. This means that all assets, liabilities, revenues, and expenses related to joint operations are reported as if they were the company’s own operations.
Early consideration of these consolidation requirements is crucial for effective CSRD reporting. By clearly mapping the organisational structure and boundaries right at the start, companies can ensure accurate identification of material impacts, risks, and opportunities (IROs), thereby setting a strong foundation for the entire reporting process and enhancing the efficiency and consistency of sustainability disclosures.
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