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Nine guiding principles for surviving CSRD
Our recommendations for staying on top of new regulations, written by Sustainability Strategist Steffie Clement.
The impending CSRD regulation is causing a fair amount of disruption among sustainability professionals at corporations across the globe. The regulation, which is set to land for approximately 50,000 organisations from as early as 2024, is predominantly focused on EU corporations but it also extends internationally. Any non-EU corporation with more than €150M net turnover in the EU and more than 1 branch in the EU will be mandated to adhere. CSRD is looming and it brings with it a whirlwind for many.
The detail and complexity of the draft requirements, coupled with the somewhat incomprehensible wording of the specifications, is leaving all perplexed and panicked – to say the least. The specifics of the regulation are still under consultation, and we’re due further updates this summer but it’s by no means ‘too early’ to start readying yourself.
At RY, we’ve been working side-by-side with clients to unravel the requirements, and to set plans in motion to keep ahead of the curve of expectation – no easy feat with a moving target.
Here are our nine guiding principles for surviving CSRD.
1. Know what you’re working from. Undertake a gap analysis to establish your baseline – how well you’re already meeting the requirements and what’s missing. Then make your plan and a roadmap to reach compliance.
Jennifer Black, Sustainability Reporting Director
“We’ve undertaken detailed CSRD gap analyses for clients. It’s proven absolutely fundamental to understanding the task ahead and laying out a pathway forward. It’s about breaking down the mountain of CSRD into realistic actions and practical steps.”
2. Be ambitious about what you want to achieve. This regulation was always intended to be tough. It’s a sign of the urgency and scale of required change. This is what marks it out from other regulation which has often enabled organisations to report but not to act. Prove your capability by rising to the challenge and embrace the spirit in which CSRD was intended.
3. But be realistic about what it’ll require to get there. The responsibility doesn’t lie with just one person or team, and certainly isn’t restricted to sustainability teams. Reach out for additional resource, training and support. CSRD is purposefully driving sustainability into the core of the business, to drive the transformation required, and so a united effort is required. Hint, you’ll really need to engage your finance and risks teams.
4. Keep track of your compliance. You won’t achieve it all in Year 1, but you can be clear on where you’ve got to and where you’re focusing on next. Aim for progress over perfection.
5. Make Double Materiality your first priority. Without it, you’ll be missing a key foundation of CSRD. Do it right and it will set you up for the best chance of success.
Louise Ayling, Sustainability Strategy Director
“CSRD has put an acute focus on double materiality. We’re lucky because we’ve already worked on many double materiality assessments, so have a strong basis to build from. Even so, we’re evolving our processes at pace to ensure we’re meeting the rigour that CSRD requires – it’s pushing impact assessment to another level.”
6. Unpick the detail, but don’t lose sight of the direction. Take the time to get to know what exactly the disclosures are demanding. But keep coming back to the disclosure objectives to guide you.
7. Keep it relevant. Keep it human. It's tempting to treat it as a compliance exercise – boxes to tick off and get done. But this approach misses the point, and critically it misses the chance to really engage your stakeholders. Tailor the disclosure to your business and to your stakeholders. Respond to the requirements, but ensure your approach and communications stays true to your organisation and communicates the bigger picture, maintaining personality and inspiration.
Connor O’Sullivan, Sustainability Analyst
"It's easy to get stuck in the weeds of CSRD & the ESRS – I’ve been there. For your own benefit, it’s important to keep a level head and remember the ultimate objective lies in aligning the disclosures of European operations with net-zero. Beyond the letter of the law, it's also the broader spirit of the law that matters here."
8. Document as you go. Do yourself – and your auditors – a favour by keeping records of what you did and your methodologies as you work. Remember, if it’s not documented, it’s not done.
9. Stay in the loop. Keep your ear to the ground for new updates and developments as they emerge and participate in the consultation where you can.
Get in touch with us to talk more about your CSRD plan.