What Does the CSRD Mean for Non-EU Companies?

While the regulation is designed for companies operating within the European market, many non-EU businesses may also fall within its scope due to their European subsidiaries, branches, or revenue generated in the region.

For affected organizations, CSRD introduces new expectations around sustainability disclosures, governance, and data management. Even companies that are not directly subject to the regulation may face growing requests for environmental, social, and governance (ESG) data from customers, investors, and partners who are required to report.

This guide explains which non-EU companies are covered by CSRD, what reporting requirements may apply, and how organizations can prepare for evolving sustainability disclosure obligations.

Why the CSRD matters for non-EU companies

The CSRD was introduced to improve the quality, consistency, and transparency of sustainability reporting across the European market. 

By establishing a common reporting framework through the European Sustainability Reporting Standards (ESRS), the regulation aims to give investors, regulators, customers, and other stakeholders access to more reliable sustainability information.

For non-EU companies, the regulation can have implications in several areas:

• Direct reporting obligations for organizations that meet the CSRD’s scope requirements.
• Greater scrutiny of sustainability data from investors, regulators, and business partners.
• Increased reporting expectations across value chains, particularly for suppliers supporting companies subject to CSRD.
• New governance and data management requirements to support sustainability disclosures and assurance processes.

The regulation also reinforces the importance of double materiality assessments, requiring organizations to evaluate both how sustainability issues affect their businesses and how their activities affect society and the environment. 

As sustainability reporting expectations continue to evolve globally, many non-EU businesses are using CSRD preparation as an opportunity to strengthen ESG data collection, reporting processes, and governance frameworks.

What non-EU companies are covered by the CSRD?

While the CSRD is an EU regulation, it can also apply to companies headquartered outside the European Union if they have significant operations within the region.

Following the Omnibus proposals and subsequent approvals, the scope of the CSRD has been narrowed, and that has increased the thresholds that determine which organizations are required to report. 

Under the current framework, non-EU companies may fall within scope if they:

• Employ more than 1,000 people globally
• Generate more than €450 million in annual revenue within the EU
• Have an EU subsidiary or branch generating more than €200 million in turnover

The exact reporting obligations depend on factors such as corporate structure, the size of EU operations, and the latest regulatory requirements.

Note: The CSRD does not apply to securities listed on EU multilateral trading facilities.

Note: The CSRD applies to EEA states which are not part of the EU, including Norway, Iceland and Liechtenstein.

What do non-EU companies need to report under CSRD?

For non-EU companies that fall within the scope of the CSRD, reporting requirements are largely aligned with those for EU-based organizations. 

While reporting requirements vary depending on an organization’s activities and material sustainability topics, several core areas are commonly included.

Double materiality assessments

The CSRD requires organizations to assess sustainability issues from two perspectives. Companies must evaluate how environmental and social issues affect their business, while also reporting on how their operations impact people and the environment. 

This process, known as double materiality, helps determine which topics should be included in sustainability disclosures.

Climate and environmental disclosures

Many organizations will need to report information related to climate change, including greenhouse gas emissions, climate-related risks and opportunities, energy consumption, and emissions reduction initiatives. 

Depending on materiality, disclosures may also cover biodiversity, water use, pollution, and resource management.

Governance and risk management

The CSRD places significant emphasis on governance. Organizations may need to disclose how sustainability is incorporated into decision-making processes, oversight structures, policies, risk management frameworks, and long-term business strategy.

Workforce and social topics

Reporting requirements can extend to employee-related topics such as working conditions, diversity and inclusion, health and safety, training, and human rights considerations. 

Companies may also need to assess the impact of their operations on workers throughout their value chain.

Value chain reporting

Many sustainability impacts and risks occur beyond an organization’s direct operations. As a result, CSRD reporting may require companies to gather Scope 3 emissions data from suppliers, partners, and other stakeholders across the value chain. This can make data collection and coordination one of the most challenging aspects of compliance.

Many organizations rely on CSRD reporting software to centralize sustainability data, manage disclosures, and improve reporting readiness across multiple entities and stakeholders.

While the Omnibus reforms have reduced the overall number of required disclosures, organizations still need reliable sustainability data, governance processes, and reporting workflows to meet their obligations. 

Preparing early can help reduce reporting challenges and improve the quality of future disclosures.

Why non-EU companies should pay attention even if they’re not in scope

Even if your organization does not currently meet the thresholds for mandatory CSRD reporting, the regulation may still affect your business.

Many companies that fall within the scope of the CSRD are required to collect sustainability information across their value chains. As a result, suppliers, partners, and service providers may increasingly receive requests for sustainability data, regardless of whether they are directly subject to the regulation themselves.

Several factors are driving this trend:

• Customer reporting requirements: Organizations reporting under CSRD may need sustainability information from suppliers and business partners to support their own disclosures.
• Value chain transparency: Companies are under increasing pressure to understand sustainability risks and impacts throughout their operations and supply chains.
• Investor expectations: Investors continue to seek more consistent and reliable sustainability data when assessing risk, performance, and long-term value creation.
• Procurement and commercial opportunities: Sustainability disclosures are becoming a more common requirement in procurement processes, supplier assessments, and commercial partnerships.

For many non-EU organizations, the question is no longer whether sustainability data will be requested, but how quickly those requests will become part of doing business in global markets.

Building stronger sustainability data collection, governance, and reporting processes today can help organizations respond more efficiently to customer requirements, support future compliance obligations, and improve visibility into their own sustainability performance.

Reporting accommodations

Under the CSRD, if your company is based outside the EU but has subsidiaries within the EU, you can create a single report that covers all reporting obligations for your EU subsidiaries. 

This helps make sure you follow the same reporting rules as EU-based companies, giving you a clear idea of what you need to report in the future.

How can Sweep help with the CSRD?

• The CSRD ready-to-use indicators and questionnaires developed by our experts enable you to efficiently gather all the disclosure-related data you need.
• We ensure transparency and help you save precious time thanks to automation and digitalization.
• Skip the headache and let the platform manage all the calculations and aggregations for you.
• The tool is easy to use for you and the companies in your value chain, with all the support and guidance you need to kickstart your journey.

Find out more about how Sweep helps organizations collect sustainability data, streamline disclosures, and prepare for CSRD reporting.