CSR Indicators in 2026: What Changes with the CSRD

Updated 12 May 2026. CSR indicators have changed in nature since the entry into force of the CSRD Directive (2022/2464 of 14 December 2022), transposed into French law by Ordinance 2023-1142 of 6 December 2023 and Decree 2023-1394 of 30 December 2023. They are no longer a communication exercise but a standardised framework built on 12 ESRS standards, a double materiality principle and a mandatory limited audit. For financial years opened in 2025, large non-listed companies exceeding 250 employees and €50M turnover (or €25M balance sheet) are, in principle, within scope — subject to the effect of the Omnibus "Stop the clock" package voted in April 2025. For an SME or mid-sized company in Paris, whether in scope directly or as a supplier to a large group, the 2026 trade-off is no longer about choosing KPIs: it is about structuring an enforceable, auditable and strategy-relevant report. At Cabinet Hayot Expertise in Paris, we support these processes for SME and growth mid-sized company cases, in direct connection with our outsourced CFO service and our Paris 8 accounting team.

CSRD Directive 2022/2464 and transposition by Ordinance 2023-1142#

Directive (EU) 2022/2464 of 14 December 2022, known as CSRD (Corporate Sustainability Reporting Directive), overhauls non-financial reporting obligations in Europe. It was transposed into French law by Ordinance No. 2023-1142 of 6 December 2023 and specified by Decree No. 2023-1394 of 30 December 2023, which amended Article L225-102-1 of the Commercial Code. The sustainability report now replaces the Non-Financial Performance Declaration (DPEF) inherited from Directive NFRD 2014/95/EU. It is included in the management report, follows a tagged digital format (XBRL tags) and is subject to a limited audit carried out by a statutory auditor or a sustainability auditor approved by the H2A (French High Audit Authority). Evolution towards a reasonable audit is planned at a later horizon, subject to a complementary European text.

The 12 ESRS standards published by EFRAG#

The European Sustainability Reporting Standards (ESRS) were developed by EFRAG and adopted by Delegated Regulation (EU) 2023/2772. They comprise 12 standards: ESRS 1 (general principles), ESRS 2 (cross-cutting general disclosures), 5 environmental standards (E1 climate change, E2 pollution, E3 water and marine resources, E4 biodiversity and ecosystems, E5 resource use and circular economy), 4 social standards (S1 own workforce, S2 workers in the value chain, S3 affected communities, S4 consumers and end-users), and 1 governance standard (G1 business conduct). ESRS 1 and 2 always apply; the other 10 standards apply subject to materiality, except ESRS E1, which requires a substantiated explanation in case of non-materiality.

Application timetable and Omnibus "Stop the clock"#

The French timetable issued by Ordinance 2023-1142 provided for four waves. Wave 1, financial years 2024 published in 2025: large listed companies and large public-interest entities with more than 500 employees (already subject to the NFRD). Wave 2, financial years 2025 published in 2026: other large companies exceeding 2 of the 3 thresholds (250 employees, €50M net turnover, €25M total balance sheet). Wave 3, financial years 2026 published in 2027: listed SMEs and certain equivalent structures. Wave 4, financial years 2028 published in 2029: third-country undertakings generating more than €150M of turnover in the EU.

The Omnibus package voted in April 2025 ("Stop the clock") postponed waves 3 and 4 by 2 years, deferring them to 2029 and 2031 respectively, and opened a possible revision of wave 2 thresholds. At 12 May 2026, the exact state of the Omnibus transposition decrees in French law remains to be verified line by line: we recommend a quarterly review of the consolidated text by finance teams, as the framework remains in motion at the closing date.

Impact materiality vs financial materiality#

The CSRD introduces a central principle: double materiality. Impact materiality measures the effects of the company on the environment and people (negative or positive impacts, actual or potential, short, medium or long term). Financial materiality conversely measures the effects of ESG issues on the company's financial situation (financial risks, opportunities, cost of capital, access to financing). A topic is material — and therefore to be reported — as soon as it crosses the materiality threshold in either of the two dimensions. This logic significantly broadens the scope compared to the DPEF, which only retained a partial financial materiality approach.

Assessment methodology#

The double materiality analysis follows five practical steps: mapping the upstream and downstream value chain (tier 1 and tier 2 suppliers, customers, end-users, product end-of-life), identifying Impacts, Risks and Opportunities (IROs) per ESRS topic, structured stakeholder dialogue (employees, customers, suppliers, NGOs, local communities, financiers), scoring IROs based on scale, scope and irremediable character on the impact side, and probability × severity on the financial side, then setting the materiality threshold. EFRAG published an application guide (IG 1) in May 2024 that serves as a reference. Documentation must be retained and made auditable, generally for 10 years.

Documentation and limited audit#

The limited audit — limited assurance — is carried out by a statutory auditor or a sustainability auditor on the H2A list. It covers the double materiality process, the conformity of published information with the ESRS and taxonomy information. Its depth is lower than a reasonable audit, but the evidence requirements remain real. For practical preparation arrangements, see our article on CSR audit and certification 2026.

GHG inventory scope 1, 2, 3 and climate strategy#

ESRS E1 (Climate change) is the cornerstone of the environmental section. It requires publication of greenhouse gas emissions in tCO₂e across three perimeters. Scope 1: direct emissions from controlled sources (gas combustion, heating oil, company vehicles, refrigerant leaks). Scope 2: indirect emissions linked to purchased energy consumption (electricity, heat, steam, cold), published on both location-based and market-based methods. Scope 3: 15 categories covering upstream activities (purchases of goods and services, upstream transport, capital goods, business travel, waste) and downstream (downstream transport, use of sold products, end-of-life, franchises, investments). E1 also requires a climate transition plan aligned with the Paris Agreement (1.5°C trajectory) and ideally validated by the SBTi (Science Based Targets initiative). An 80-employee SME typically publishes 1,200 to 3,500 tCO₂e for scope 1+2; scope 3 most often represents 70 to 90% of the total.

Water, waste, pollution, biodiversity#

ESRS E2 (Pollution) covers emissions to air, water and soil, as well as substances of concern (SVHCs under the REACH regulation). ESRS E3 (Water and marine resources) requires publication of water volumes withdrawn, consumed and discharged (m³), with a focus on water-stressed areas identified via the WRI Aqueduct tool. ESRS E4 (Biodiversity and ecosystems) requires mapping of sites in sensitive zones (Natura 2000, ZNIEFF, IUCN), the pressures exerted and biodiversity transition plans. ESRS E5 (Circular economy) covers inflows (raw materials, renewable resources), outflows (products, by-products, packaging) and waste valorisation rates.

Bilan Carbone ADEME and GHG Protocol method#

The French reference method is the Bilan Carbone published by ADEME, compatible with the GHG Protocol and compatible with the regulatory GHG inventory (BEGES) under Article L229-25 of the Environmental Code. The national platform bilans-ges.ademe.fr centralises emission factors from the Base Carbone and hosts the mandatory BEGES filing, due every 3 years since the Climate & Resilience Law 2021 (down from 4 years previously). The GHG Protocol Corporate Standard and the GHG Protocol Scope 3 Standard are the equivalent international references, complemented by CDP (Carbon Disclosure Project) for large listed groups. Methodological costs incurred as part of dedicated research may, in some cases, qualify for the Research Tax Credit (CIR) — case-by-case verification.

Headcount, gender balance, French gender equality index#

ESRS S1 (Own workforce) requires publication of total headcount, broken down by permanent/fixed-term contracts, full-time/part-time, by gender, age range, country, in average full-time equivalent over the financial year. It also covers the gender pay gap, expressed as a percentage. This indicator partly overlaps with the French gender equality index (so-called Pénicaud index), codified in Articles L1142-7 and following of the Labour Code for all companies with more than 50 employees: a score out of 100 calculated on 5 indicators (pay gap 40 points, pay rise gap 20 points, promotion gap 15 points for > 250 employees, pay rises on return from maternity leave 15 points, women among the 10 highest earners 10 points). A score below 75 requires corrective measures over 3 years, under penalty of a fine of up to 1% of the payroll.

Safety (TF1/TG1), training, turnover#

ESRS S1 also requires health and safety indicators. The Frequency Rate TF1 = (number of lost-time accidents × 1,000,000) / hours worked. The Severity Rate TG1 = (number of lost days × 1,000) / hours worked. ISO 45001 reference for occupational health and safety management. Turnover must be published as a percentage (departures / average headcount), as well as training hours per employee per year, and the percentage of training expenditure relative to payroll (beyond the legal minimum of 1% for companies with more than 10 employees). Absenteeism is expressed as % of hours absent over theoretical hours.

Diversity, disability, value chain#

Article L5212-13 of the Labour Code imposes on companies with more than 20 employees a 6% quota of disabled workers (OETH), with an AGEFIPH contribution in case of non-compliance. ESRS S1 requires disclosure of the share of disabled employees, the presence rate of minorities or under-represented groups depending on national contexts. ESRS S2 (Workers in the value chain) extends the scope to subcontractors and suppliers: working conditions, living wage, freedom of association, child labour — particularly sensitive issues for the textile, agri-food and electronics sectors. ESRS S3 (Affected communities) and ESRS S4 (Consumers) complete the framework.

Board, parity, independence#

ESRS G1 covers business conduct. The composition of the administrative or supervisory body must be published: number of directors, independence (within the meaning of the AFEP-MEDEF Code for listed companies), gender parity (Copé-Zimmermann Law extended by the Rixain Law 2021-1774: 40% of each gender on the executive committee by 2030 for companies with more than 1,000 employees), diversity of skills. Attendance rate at meetings and the number of specialised committees (audit, remuneration, CSR) are also expected indicators.

Anti-corruption Sapin II Law and whistleblower#

The Sapin II Law No. 2016-1691 of 9 December 2016 requires companies with more than 500 employees and €100M turnover to implement a complete anti-corruption system: code of conduct, risk mapping, third-party assessment procedures, accounting controls, training, internal alert system and disciplinary regime. The Waserman Law No. 2022-401 of 21 March 2022 strengthened the whistleblower status. ESRS G1 requires publication of confirmed incident cases, corrective actions and the number of reports handled through the alert system.

Tax policy and cybersecurity#

Tax transparency is one of the expected topics: group tax policy, presence in privileged-tax jurisdictions, public Country-by-Country Reporting (CbCR) compulsory since Directive (EU) 2021/2101 for groups exceeding €750M of consolidated turnover. Cybersecurity and personal data protection (GDPR) form a rising component: number of incidents notified to the CNIL, business continuity plans, cyber-risk training. See our article on the digitalisation of companies for the IT tooling side.

Gender equality index L1142-7 for companies > 50 employees#

Independently of the CSRD, the gender equality index remains required for any French company with more than 50 employees and must be published on the website and declared to the DREETS every 1 March. The calculation method varies according to headcount (50-250 employees vs > 250 employees). It is the only CSR indicator that carries a direct financial penalty in case of prolonged inaction.

GHG inventory L229-25 for companies > 500 employees#

Article L229-25 of the Environmental Code imposes the regulatory GHG inventory (BEGES) on companies with more than 500 employees in mainland France (250 in overseas territories), public bodies with more than 250 agents and local authorities with more than 50,000 inhabitants. The frequency has been reduced to 3 years by the Climate & Resilience Law 2021-1104, down from 4 years previously. The transition plan is now mandatory and enforceable, filed on the ADEME platform bilans-ges.ademe.fr. Failure to publish exposes to an administrative fine of up to €50,000 (€10,000 for a first breach, doubled in case of repeat).

EU green taxonomy and SFDR#

Regulation (EU) 2020/852, known as the green taxonomy, requires CSRD companies to disclose the share of their turnover, CapEx and OpEx aligned with the 6 environmental objectives (climate mitigation, adaptation, water, circular economy, pollution, biodiversity). Regulation (EU) 2019/2088 known as SFDR (Sustainable Finance Disclosure Regulation) applies to asset managers and conditions the classification of a product under Article 6, 8 or 9. A non-financial company remains indirectly impacted: its ESG indicators feed the SFDR obligations of its investors.

The trade-off — CSRD anticipation vs minimal reporting#

In the SME and mid-sized company files we support in Paris, the strategic trade-off is not just about the obligation timetable. Three scenarios stand out. A large company in scope for wave 2 (2025 financial year published in 2026) must deploy a complete system immediately, with double materiality analysis, ESG governance, IT tooling and limited audit budget. A mid-sized company outside the direct scope but supplier to a CSRD-bound principal has every interest in anticipating on a lightweight ESRS base, calibrated on the indicators required by its customers. A standalone out-of-scope SME may limit itself to the EFRAG voluntary VSME standard, focusing on what creates value: EcoVadis score if it sells B2B, B Corp label if the internal culture aligns, ISO 14001, ISO 26000 or ISO 45001 certifications depending on the activity.

The underestimated risk — value chain and indirect scope 3#

The most frequent risk observed at our clients lies with scope 3 and the value chain. A non-subject SME thinks it is not concerned — and yet receives ESG data requests from its large-group customers for their own CSRD obligations: emission factors per product sold, recycled material rates, payroll dedicated to low-carbon R&D, social indicators of production sites. A Paris-based SME supplier to a large listed group may, as of 2026, see 30 to 40% of the weighting of a public tender or framework contract depend on this data. The conditionality of public aid (BPI France, France 2030, sector plans) also integrates growing CSR criteria. The best defence remains a minimum base of 15 to 25 reliable indicators, explicit ESG governance and an accessible audit trail — work we conduct in connection with the structuring of CSR reporting.