In brief: The EU has narrowed CSRD reporting to the largest organisations and reduced the pressure on smaller companies to provide extensive value-chain data. The clear direction of travel remains the same: credible, auditable sustainability data will increasingly be expected, even where reporting is voluntary.
A quick reminder: what is CSRD?
The Corporate Sustainability Reporting Directive (CSRD) is the EU’s framework for improving the quality, consistency, and comparability of sustainability reporting across environmental, social and governance (ESG) topics. It expands and strengthens earlier non-financial reporting expectations by pushing companies towards more structured disclosures and greater assurance over sustainability information. In practical terms, CSRD is driving organisations to treat sustainability data with similar discipline to financial data.
The big change: who is in scope now?
The December 2025 Omnibus I simplification package is intended to narrow CSRD’s scope and reduce administrative burden. Commentary from the CSRD reporting ecosystem indicates a stronger focus on organisations with substantial scale, commonly framed as:
- 1,000+ employees
- €450m+ net annual turnover
A major consequence is that listed SMEs are no longer in mandatory scope under this simplification approach. For many mid-sized organisations, this shifts the task from “urgent compliance delivery” to “strategic readiness.”
The real practical shift: supply chain pressure should reduce
For many sustainability teams, the most difficult part of CSRD readiness has been Scope 3 emissions and value-chain information requests.
The December changes include an important signal: companies with fewer than 1,000 employees are not expected to provide exhaustive value-chain data to larger partners beyond what is covered in voluntary standards. As a result, larger organisations may rely more on estimates and proxies where primary supplier data is disproportionate or unavailable. Data quality still matters, but the expectation becomes more proportionate and targeted.
What you should do now
1) Confirm your status
Do not assume. Check whether you remain in scope based on the revised thresholds and your corporate structure.
2) Build strong, auditable operational data
Whether you are a large organisation reporting under CSRD or a smaller one responding to customers and investors, the foundational requirement is the same: reliable data for electricity, gas, water and fuels, plus clear calculation logic.
3) Use recognised verification frameworks for credibility
This is where ISO 14064 becomes highly relevant. ISO 14064 provides a structured basis for quantifying and verifying greenhouse gas emissions, supporting credible reporting and helping organisations prepare for increasing assurance expectations over time.
4) Invest in monitoring that makes reporting easier
Even with simplification, the direction of travel is towards more consistent, measurable, defensible sustainability reporting. That requires monitoring, not guesswork. A practical route is to implement robust utility and sub-meter monitoring to capture high-frequency, traceable data that supports both internal decisions and external disclosures.
Senzio’s monitoring solutions are designed to help organisations of all sizes establish that data foundation: larger organisations can strengthen assurance-readiness and reporting efficiency, while smaller organisations can respond to stakeholder requests with confidence and avoid ad-hoc, manual data collection.