Policy Briefing — CSRD first-wave sustainability statements lock for FY 2024 year-end filings
Large EU public-interest entities must publish CSRD-aligned FY 2024 sustainability statements in 2025, making December the final checkpoint to validate ESRS disclosures, assurance evidence, and XBRL tagging before board approval.
Executive briefing: Directive (EU) 2022/2464 (the Corporate Sustainability Reporting Directive, CSRD) applies from financial years starting on or after 1 January 2024 for large EU public-interest entities with more than 500 employees. Those companies must include a CSRD sustainability statement in their 2025 management reports, covering the FY 2024 period, alongside limited assurance opinions. December 2025 is the last window to finalise European Sustainability Reporting Standards (ESRS) metrics, double materiality conclusions, and digital tagging artefacts before filing deadlines.
Mandatory deliverables
- ESRS disclosures. Article 19a requires narrative and quantitative reporting across ESRS environmental, social, and governance topics, including scenario analysis, transition plans, and value-chain metrics.
- Assurance readiness. Article 26 mandates limited assurance over the sustainability statement, demanding evidence packages, control testing, and audit committee oversight.
- Digital reporting. Article 29d obliges undertakings to prepare sustainability statements in the European Single Electronic Format (ESEF) with XBRL tagging aligned to the ESRS taxonomy.
Program actions
- Data validation. Run reconciliation checks between sustainability data warehouses, financial systems, and ESRS KPIs to ensure accuracy and traceability.
- Control walkthroughs. Coordinate internal audit, finance, and sustainability teams to evidence control design and operating effectiveness ahead of limited assurance procedures.
- Board governance. Schedule audit committee reviews of double materiality outcomes, transition plan narratives, and assurance findings before final approval.
Enablement moves
- Align narrative disclosures with EU Taxonomy, SFDR, and ISSB references to demonstrate cross-framework consistency.
- Complete ESEF tagging dry runs and validation checks to avoid filing rejections by national authorities.