CSRD lands on your Indian entity through your EU parent or your EU customer.
Double materiality is the concept that traps most companies. Both directions, both angles, both audiences.
Runs on your public disclosures. Nothing from you.
You are the CFO or Group Sustainability Head at an Indian company with an EU subsidiary or an EU parent above the CSRD threshold. Your EU parent files its first report under the revised scope on FY 2027 data, in 2028. Your Indian entity is inside the group boundary.
The Corporate Sustainability Reporting Directive (CSRD) was rewritten by Directive (EU) 2026/470 of 24 February 2026, published in the Official Journal on 26 February 2026 and in force from 18 March 2026. It now catches EU undertakings with more than 1,000 employees and net turnover above EUR 450 million. Both tests must be met. Obligations apply for financial years starting on or after 1 January 2027, so the first reports under the revised scope cover FY 2027 and are filed in 2028. Non-EU parent companies with EUR 450 million of net EU turnover in each of the last two consecutive financial years, plus an EU subsidiary above EUR 200 million or a branch above EUR 50 million, report from FY 2028. Reporting follows the European Sustainability Reporting Standards (ESRS), sits inside the management report, and carries limited assurance.
What CSRD actually is
CSRD applies to EU undertakings that clear both tests: more than 1,000 employees and net turnover above EUR 450 million. The old two-of-three test (250 staff, EUR 50M turnover, EUR 25M assets) is gone, and listed SMEs are out of scope entirely. Member States may grant first-wave companies that now fall below the thresholds a transitional exemption for financial years beginning 1 January 2025 to 31 December 2026. Non-EU parents come in on FY 2028 data, filed in 2029.
The reporting standard is ESRS Set 1: ten topical standards covering climate (E1), pollution (E2), water (E3), biodiversity (E4), circular economy (E5), workforce and value chain (S1 to S4) and business conduct (G1), plus two cross-cutting standards, ESRS 1 and ESRS 2. Twelve in total.
The double materiality assessment is the entry gate. A topic is material if it affects the company (financial materiality) or if the company affects people or the environment (impact materiality). Both directions must be assessed and documented.
Why now
The Omnibus I package, adopted as Directive (EU) 2026/470, cut the scope and moved the dates. It did not change the direction. Member States must transpose by 19 March 2027, and assurance standards are due by 1 July 2027. FY 2027 is the first reporting year under the revised scope, so the data collection that feeds it starts in January 2027. Indian entities inside EU groups get the data request before that.
What breaks when your carbon number is not defensible.
Three failure modes that recur on CSRD scans.
One-directional materiality
The company assesses financial materiality only. The impact side stays blank. ESRS 2 requires both. The filing is incomplete.
Scope 3 without a value-chain map
A Scope 3 number without a documented value-chain map does not satisfy E1. The auditor asks for the map. It does not exist.
Governance disclosures written in the boilerplate voice
Board oversight of climate written as generic paragraphs. ESRS 2 GOV-1 and GOV-3 ask for named committees, cadences, and decisions. Generic answers get flagged.
Three moves that make CSRD defensible.
Double materiality documented, not asserted
Carbon-OS runs the double-materiality assessment with a documented workflow: stakeholders consulted, impacts scored, evidence attached.
Value-chain map built into the tool
Suppliers, customers, use-phase, end-of-life are all mapped as first-class objects. Scope 3 categories tie back to the map.
ESRS-tagged output, ready for XBRL
Every disclosure is tagged to the ESRS datapoint. Digital tagging is mandated in principle but not yet applicable, pending the ESMA sustainability taxonomy. The tags are in place for the day it lands.
See where your CSRD number stands. Free scan.
Run the free Carbon X-Ray →What people ask, straight.
Does CSRD apply to my Indian company directly?
Only if you have an EU subsidiary above the threshold, or an EU parent that consolidates you, or your group books more than EUR 450M of net EU turnover in each of the last two consecutive financial years with an EU subsidiary above EUR 200M or a branch above EUR 50M. Otherwise, you are asked to provide data upward, not to file directly.
When does the non-EU parent obligation start?
FY 2028, with first filings in 2029. The trigger is EUR 450M of net EU turnover in each of the last two consecutive financial years, plus an EU subsidiary above EUR 200M or a branch above EUR 50M. The earlier EUR 150M trigger no longer applies.
How is CSRD different from CSDDD?
CSRD is disclosure. The Corporate Sustainability Due Diligence Directive (CSDDD) is action: due diligence obligations on the value chain. Separate directives, related audiences.
What is "double materiality"?
A topic is material if it affects the company financially, or if the company affects people or the environment. ESRS requires you to assess and disclose both directions for every topic.
Do we need XBRL?
Not yet. Digital tagging of the sustainability statement is mandated in principle, but it does not apply until ESMA finalises the sustainability reporting taxonomy. Tag your datapoints now so the export is ready when the taxonomy is published.
Is reasonable assurance coming?
No. The step up from limited to reasonable assurance did not survive the 2026 revision. Limited assurance is what applies. The assurance standards themselves are due by 1 July 2027.