Impacts, Risks, and Opportunities (IRO) for CSRD Reporting
1 min
Level
In this article, we’ll break down what IROs are, how to identify and assess them, and what CSRD requires in terms of disclosure.
ESG / CSR
Industries
MEASURE
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COMFORM
Checklist: The 7 steps to start your CSRD compliance
Level
The CSRD (Corporate Sustainability Reporting Directive) imposes new requirements for non-financial reporting. Here’s a straightforward guide to start your compliance journey, without any unnecessary jargon:
1. Check if your company is affected
The CSRD applies to certain EU and non-EU companies based on their size, listing status, and EU economic presence. Following the Omnibus I simplification package, the scope has been significantly narrowed and now targets the largest organisations with the greatest sustainability impact.
As a starting point, companies potentially in scope include:
- Large EU companies (listed or unlisted) with at least 1,000 employees and either €450+ million in net turnover or €25+ million in total assets;
- Non-EU companies generating €450+ million in EU turnover for two consecutive years and having a significant EU presence through a large subsidiary or branch;
- Companies previously subject to the NFRD, which remain in scope under transitional rules.
⚠️ Important: Companies with fewer than 1,000 employees are now classified as Protected Undertakings and are exempt from mandatory CSRD reporting. Listed SMEs are also no longer required to report under the CSRD. Applicability should be assessed based on the latest confirmed rules, not legacy CSRD timelines.
For companies that remain in scope, CSRD reporting is being introduced in waves, with reporting dates depending on company size, listing status, and location:
- 2025 reporting (FY 2024): Companies already subject to the NFRD.
- 2028 reporting (FY 2027): Large EU companies meeting the post–Omnibus I thresholds (≥1,000 employees).
- 2029 reporting (FY 2028): Non-EU parent companies with significant EU activity under the Omnibus I criteria.
However, recent regulatory updates and proposed simplifications may delay or remove reporting obligations for certain companies, particularly in later waves. As a result, businesses should:
- Confirm their reporting wave based on the current CSRD framework and latest EU guidance;
- Monitor regulatory updates affecting scope and timelines;
- Continue preparing where CSRD applicability is likely, even if reporting is deferred.
2. Familiarise yourself with the key principles
- Double materiality: Examine both the impact of your activities on the environment and society (environmental/social materiality) and the impact of social and environmental issues on your financial performance (financial materiality). Learn more.
- ESRS Standards: The European Sustainability Reporting Standards define the precise framework for structuring your reports and help you identify the themes you need to address (e.g., greenhouse gas emissions, respect for human rights). Learn more.
3. Identify your internal and external stakeholders
Engage your stakeholders early to collect precise and relevant data.
- Internally: Financial officers, HR, production teams, etc.
- Externally: Clients, suppliers, investors, regulators.
- Goal: Mobilize internal and external resources to ease data collection.
4. Centralise your ESG data
- Inventory: Take stock of available data (e.g., CO₂ emissions, social practices).
- Tools Setup: Automate data collection with dedicated software. This reduces processing time and improves the reliability of the results.
5. Perform a double materiality analysis
- Identify impacts, risks, and opportunities (IROs) relevant to your activities and value chain.
- Assess impact and financial materiality separately, using documented criteria and scoring.
- Document the methodology, assumptions, and thresholds used to determine material topics.
- Use a materiality matrix as a visual output, not as the assessment itself.
6. Plan your report
- Prepare a draft: Structure your information to meet ESRS standards.
- Ensure compliance: Have your indicators validated by experts to ensure they meet regulatory requirements.
7. Get expert support
CSRD compliance requires methodological rigour, traceability, and audit readiness. Platforms like Greenly can support companies with:
- EFRAG-aligned double materiality assessments;
- Structured ESRS data collection across all disclosure requirements;
- Audit-ready documentation and compliant reporting outputs;
- Ongoing guidance to help teams build autonomy over time.
Learn more in the Greenly Guide on CSRD methodology.
Start today
Being CSRD compliant is an opportunity to turn your obligations into a strategic lever. You have the keys: it’s your move!
For tailored support, book a demo with our experts here.
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