European Commission increases CSRD large undertaking thresholds

The European Commission has adopted a delegated act that adjusts the size thresholds for large undertakings. Large undertakings have reporting obligations under the EU’s Corporate Sustainability Reporting Directive (the categorization is relevant for other purposes as well).

Balance sheet: Increases from €20 million to €25 million.

Turnover: Increases from €40 million to €50 million.

Employees (average number): Unchanged at 250.

The delegated act amends the size thresholds in the Accounting Directive. That directive provides the legal framework for the preparation, presentation, publication and audit of individual and consolidated annual financial statements for EU undertakings. The classification of an undertaking as large is based on meeting two out of the three size thresholds above.

The new thresholds will apply for financial years beginning on or after January 1, 2024. However, EU member states may allow undertakings to apply the new thresholds for the financial year beginning on or after January 1, 2023. 

The amendments are subject to review by the European Council and Parliament. There is a two-month review period that runs through mid-December. If neither of those bodies objects during the review period, the amendments will come into force. The expectation is that this will occur.

The reporting threshold increase is part of the European Commission’s efforts to reduce reporting burdens by 25% without undermining related policy objectives. The Accounting Directive requires the Commission to review the monetary size criteria every five years and, where appropriate, adjust the size criteria for the effects of inflation. The Commission estimates that as a result of this change the number of large undertakings will decrease from 82,986 to 71,372.

The delegated act also increases the thresholds for “micro,” “small” and “medium” undertakings. Those changes are not discussed in this post.

Takeaways 

• The new thresholds should be used for CSRD large undertaking scoping as companies assess the applicability of the CSRD and develop their workplans.
• Given the modest step-up in the thresholds, the changes are likely to only have an impact around the margins.  For most companies, their CSRD compliance obligations will not change.

Other October CSRD developments

• The European Commission released its 2024 work program. As part of that program, the Commission proposed pushing back by two years the deadline for the adoption of sector-specific CSRD reporting standards and reporting standards for non-EU companies – from June 30, 2024 to June 30, 2026. See our post.
• EFRAG published its proposed sustainability reporting work program for 2024 and beyond. Among other things, EFRAG’s work program addresses plans for CSRD guidance, development of additional European Sustainability Reporting Standards under the CSRD and development of a voluntary reporting standard, including related timing. See our post. EFRAG (previously known as the European Financial Reporting Advisory Group) is an independent, multi-stakeholder advisory body, majority funded by the EU. EFRAG provides technical advice to the European Commission on the European Sustainability Reporting Standards under the CSRD. 

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