CSRD Reporting Obligations: Priorities for Companies & Opportunities for Freelancers

The Corporate Sustainability Reporting Directive (CSRD) does not affect all companies at once – instead, it comes into force in four staggered phases. The revised schedule takes into account the so-called “Stop-the-Clock” decision of spring 2025:

1st wave – from 2024 (first reporting in 2025)
▶ Large listed companies already subject to the previous NFRD (Non-Financial Reporting Directive)

2nd wave – from 2027 (first reporting in 2028)
▶ Large companies that meet at least two of these criteria:

• Balance sheet total exceeding €25 million
• Net turnover exceeding €50 million
• More than 250 employees

3rd wave – from 2030 (first reporting in 2031)

▶ Listed SMEs (small and medium-sized enterprises)

• Reporting obligation from financial year 2030
• Applies only if listed (e.g. on stock exchanges)
• Micro-enterprises are exempt
• Especially relevant for European domestic markets

▶ Non-EU companies with significant EU presence

• Also reporting obligation from financial year 2030
• Applies, for example, if:
   • Turnover exceeds €150 million within the EU
   • Or there is a large subsidiary in the EU
   • Or large branch (with turnover over €40 million)

Note: The Omnibus draft of 26 February 2025 proposes to raise the thresholds for the second wave significantly – including to more than 1,000 employees. In Germany, a proposed bill already reflects this adjustment. While the final decision is still pending, companies that previously just fell under the threshold should watch this development closely.

Especially relevant for freelancers:
If the higher thresholds do indeed come into effect, a significant number of companies previously considered subject to the reporting obligation would fall out of the regular CSRD reporting obligation. This would directly affect demand: the focus would shift even further towards SMEs and voluntary reporting - meaning greater need for pragmatic, modular support.

Even though the timeframe has become more generous, doing nothing would be a mistake. Here's why:

• Supply chain pressure is rising: Even companies not directly affected will be soon asked by major clients to disclose ESG data.
• Group dependencies: Subsidiaries of reporting groups may also be required to report.
• Preparation pays off: Those who start building structures now will be able to report efficiently and transparently later - rather than scrambling under time pressure.

CSRD not only brings new obligations - it also introduces new perspectives. One of these is the so-called “double materiality”. In the future, companies must assess relevance in two directions:

1. Outside-in: Which sustainability topics influence the company - such as climate risks, regulatory requirements, or reputational losses?
2. Inside-out: What effects does the company’s own behavior have on the environment and society— - or example, CO₂ emissions, resource consumption, or supply chain conditions?

“It’s not enough to simply say: We’re already doing this somehow. It must be understandable and auditable.”
– Laurin Flörke

Both perspectives are compulsory- and subject to audit. Those who fail to correctly identify material topics risk failing short of the the requirements altogether.

To make sure this doesn't remain just a theory, Laurin shared several practical tips during the webinar:

• Create a materiality matrix: Start with a thourough stakeholder analysis and prioritise topics together with your specialist departments.
• Involve external support: Experts help design robust assessment logics, align relevant standards, and identify data gaps early on.
• Document everything properly: An auditable process requires clear, transparent reasoning and not gut feeling.

In short: Without structure, double materiality becomes doubly burdensome. But with the right setup, it’s a real opportunity to anchor sustainability strategically - and make reporting far more efficient.

The CSRD requires companies to report on their sustainability performance — but what should this actually look like? To clarify this, the EU has developed the European Sustainability Reporting Standards (ESRS). These standards specify in detail which topics must be covered, what metrics to report, and what qualitative information to disclose.

During the webinar, the expert emphasized: “The ESRS are not intended as recommendations - they are mandatory.”

The standards apply from the first year of reporting and require a structured, transparent approach to data. It’s not just about environmental metrics, but also about social issues, governance, and internal control systems.

The webinar also highlighted that:

• Without a central structure, things quickly become confusing: data is often collected across multiple departments, which makes clear processes and defined responsibilities even more important.
• Standardization saves effort: establishing up a sound methodology for KPIs, processes, and roles today prevents a lot of manual rework later.
• Plan for technological support: sooner or later, companies will need digital tools to record metrics efficiently and reliably, so this should be considered now.

Freelancers with expertise in data management, reporting, or ESG standards can provide early support to companies in building professional structures - long before the first report is even written.

Not every small business has to report under the CSRD straight away, but many want or need to report voluntarily. This is exactly what the VSME (Voluntary Sustainability Reporting Standard) is designed for: a simplified ESG standard designed specifically for small and medium-sized enterprises.

A voluntary European reporting standard for SMEs, which standardises the disclosure of environmental, social and governance topics, without the full complexity of the regular CSRD compliance. VSME was developed by EFRAG to enable structured and practical reporting even without a legal reporting obligation.

For all small and medium-sized enterprises that wish to report on sustainability voluntarily, whether out of personal initiative, at a partner's request, or due to gorwing ESG requirements in the supply chain.

VSME consists of two modules:

• Basic Module with core ESG metrics
• Comprehensive Module with additional information.
  In total, it covers about 20 reporting requirements with approximately 100 data points, scalable according to company size and capacity.
  

• Low-threshold entry: Structured reporting without excessive bureaucracy
• Flexible and adaptable: Suitable for craft businesses and tech start-ups alike
• Cost-efficient and scalable: Depending on maturity and resources
• Future-proof: VSME is compatible with ESRS, making later transitions easier
• Greater credibility: Companies sharing ESG data in VSME format demonstrate committment and professionalism
• Protective effect: The standard limits which ESG data large companies can request from smaller partners - a safeguard for non-reporting companies
  

With the CSRD Omnibus, many companies will fall out of the mandatory reporting scope, yet the pressure to provide ESG data remains. For these companies, VSME is becoming the preferred framework. Demand is growing, and so is the need for freelancers who can help businesses establish professional ESG reporting structures early on.

Not every company needs comprehensive ESG software right away. Especially when reporting voluntarily under the VSME standard, many requirements can initially be met without a full tool stack. Still, the principle holds: the more structured your data collection, the easier it will becomes to produce reliable reports, especially as data volumes grow or external audits come into play.

Many companies are only at the beginning of their ESG journey. Data is often collected manually, often in silos, which quickly leads to inconsistencies, inefficiencies, and unnecessary additional workload. Digital tools can significantly reduce this burden, but they aren’t strictly necessary from the start.

And this is exactly where freelancers come in:

• You support companies in finding the right-fit solutions: from pragmatic first steps to scalable tool implementation.
• You help establish clean data flows that minise manual errors.
• You introduce the structure and documentation needed to make processes traceable and audit-ready, and guide teams through the change process.
  

Conclusion: Technical tools aren’t a must, but they're often the next smart step. Your can make the difference for companies between companies simply checking boxes and building efficient, future-proof ESG reporting.

The CSRD transition is uncharted territory for many companies, and they’re actively seeking support. As a freelancer with expertise in sustainability strategy, reporting, or data management, you can make a real impact.

This is exactly where you come in, whether as a sparring partner during the strategy phase, a structuring force in the materiality analysis, or as hands-on support for tool implementation and data preparation.

• Devloping and moderating materiality analyses
• Interpreting and applying ESRS requirements
• Designing lean reporting structures
• Selecting and implementing suitable tools and KPIs
• Providing team or management training

What you should bring: Methodological know-how, a solid understanding of regulatory requirements, and the ability to translate complex topics into clear, practical guidance.

The best part: demand is growing fast. If you make yourself visible now and position yourself as a trusted guide, you won't just be needed, you'll also secure valuable, long-term projects.

For many companies, the CSRD transition is new, complex, resource-intensive, and time-pressured challenge. This creates clear opportunities for external experts who not only understand the regulations, but can also bring clarity and structure.

The webinar summed it up perfectly:
“You need someone who tells you: This is the way, these are the standards, and this is the system for how you start.”
- Laurin Flörke

As a freelancer, you can take on this role:

• Strategically: preparing materiality analysis, CSRD roadmaps.
• Technically: supporting tool setup and KPI definition
• Operationally: providing hands-on support when internal resources are stretched.

Freelancers with experience in sustainability reporting, regulation, data management, or communication are particularly sought-after, as well as strong generalists with the ability to structure and explain complex topics clearly.

Tip:
Use your Malt profile to highlight your skills, experience and the value you bring. Those who position themselves effectively now will not only secure exciting new projects, but also play a key role in this period of transformation.