CSRD 2026: The Executive Playbook to Prepare Your Company Without the Bureaucracy

The Corporate Sustainability Reporting Directive (CSRD) has entered a delicate phase. On one side, the EFRAG-issued ESRS and the French ordinance of 6 December 2023 set out a dense, technical framework, originally designed for large listed companies. On the other side, the European Commission's Omnibus simplification proposal (2026) reopens certain thresholds, postpones several deadlines and explicitly aims to lighten the reporting burden on intermediate entities. In between, many owner-managers make the wrong call: they either wait, or they launch a 12-month project with 200 indicators.

This guide proposes a third route: a 90-day roadmap to structure CSRD preparation for a French SME or mid-cap, focused on the trade-offs that only the chief executive can make. It complements our existing pieces on CSRD scope, ESG reporting and double materiality analysis, with a focus on executive steering.

Short answer (TL;DR): CSRD preparation hinges on 8 executive decisions taken in 90 days — scope, internal team, double materiality, group perimeter, choice of independent assurance provider, ESRS perimeter, closing calendar, multi-year budget. Everything else is execution. Without those 8 decisions made upfront, the project drifts into endless consultation and overruns its budget.

Three elements frame the situation in spring 2026.

The French legal framework is in place. Ordinance no. 2023-1142 of 6 December 2023, its implementing decrees and articles L. 233-28-4 et seq. of the French Commercial Code transpose the CSRD into French law. The first closed financial years are now in the operational phase. Our piece on CSRD scope in 2026 details the thresholds by category.

The Omnibus proposal partly redraws the map. In 2026, the European Commission unveiled a simplification initiative aimed at reducing the reporting load, postponing certain deadlines and refocusing the obligation on the most structuring entities. The executive consequence: it is dangerous to launch a heavy CSRD project before the final political trade-offs are confirmed. But it is equally dangerous to wait, since ESG data is already requested by banks (see our piece on ESG bank requirements) and large clients.

Independent assurance becomes a structuring topic. The statutory auditor or another accredited independent assurance provider must deliver limited assurance and, in time, reasonable assurance on sustainability information. Calendars and organisation of this assignment interact closely with the financial audit. See our pages on statutory audit and statutory auditor services.

The most frequent mistake we observe: the entire CSRD project is delegated to a CSR officer or to the CFO. But 8 decisions cannot be delegated — they bind the company over several years and determine the total cost of the framework.

To structure these decisions, many executives rely on their accountant in a CSRD reporting engagement — not to execute the project, but to frame the choices.

The roadmap below is a template. It must be adapted to ESG maturity, sector and ownership structure.

Days 1 to 15 — Scoping#

• Legal scope diagnostic (mandatory, voluntary, excluded CSRD)
• Mapping of ESG data already available (HR, energy, procurement, quality)
• Identification of key internal stakeholders
• Designation of the sustainability lead and constitution of the project committee
• First rough budget estimate (internal + external)

Days 15 to 45 — Double materiality and perimeter#

• Double materiality workshop with internal stakeholders
• Identification of material ESG topics (impact + financial)
• Selection of thematic ESRS deemed material and documented justification of exclusions
• Decision on consolidation perimeter
• Selection of the assurance provider and preliminary engagement letter

Our double materiality analysis piece outlines a 4–6 week method.

Days 45 to 75 — Building the framework#

• Translation of the selected ESRS indicators into a data collection plan
• Designation of business contributors (HR, procurement, energy, quality, legal officers)
• Documentation of internal procedures (who collects, frequency, primary source)
• Construction of an audit-ready evidence file anticipating assurance expectations
• First dry run on 1 or 2 critical indicators

Our piece on preparing for ESG assurance in 2026 details the level of evidence expected.

Days 75 to 90 — Governance and calendar#

• Approval by the board or partners
• Scheduling of the sustainability report closing calendar (aligned with financial closing)
• Contracting of the assurance provider
• Internal and external communication plan
• Training plan for the executive and the board

At the end of these 90 days, the company has an operational but minimalistic framework — precisely the goal. Subsequent iterations happen one financial year at a time, without a "big bang" project.

Three lessons learned from advising French mid-caps and French subsidiaries of foreign groups over the past 18 months.

Don't confuse CSRD with the wider CSR strategy. CSRD is a reporting exercise. It does not replace the CSR strategy, nor does it precede it. Many executives fall into the "total CSR project" trap on the back of CSRD, multiplying costs without serving compliance.

Recurring cost typically exceeds initial cost. Year-one cost frequently lies between €80,000 and €250,000 for a French mid-cap depending on complexity, but recurring annual costs (data collection, assurance, updates) are structurally underestimated. Anticipating an annual operating budget of 30 to 80 % of the entry cost is a prudent working assumption, to be calibrated case by case.

Coordination with the financial audit is underestimated. The assurance provider expects auditable data: audit trails, traceability, internal controls. Existing finance processes (e.g. inventory, payroll) serve as a model; but ESG data (energy, waste, suppliers) often relies on lightly governed systems. See our recommended CSR indicators.

The least well-identified risk is neither technical complexity nor cost: it is operational rigidification. A company publishing in year one a sustainability report with a given perimeter, given methods and given indicators must maintain comparability in subsequent years.

Practical consequences:

• Any change of indicator must be justified and explained (with restatement of past data).
• Commitments made in the report (CO₂ targets, share of renewable energy, etc.) become enforceable by stakeholders (clients, banks, NGOs, employees).
• A subsidiary disposal can disrupt the published trajectory and require restatement.
• Assurance providers expect consistency between the sustainability report and the company's other communications (website, marketing, fundraising materials).

This rigidification is not a flaw: it is precisely the goal of the CSRD. But it argues for starting small and committing only to what can be sustained over five years.

90 days into the project, the executive should have settled:

• CSRD scope validated by a legal opinion (mandatory, voluntary, exempt)
• Sustainability lead identified, role description updated
• Project committee with executive sponsor in place
• Double materiality method and ambition agreed
• Consolidation perimeter set
• Assurance provider selected, engagement letter signed
• List of material ESRS formalised and justified
• Multi-year budget approved by the board
• Closing calendar aligned with financial closing
• Training plan for executive + board

Without those 10 boxes ticked, the CSRD project remains exposed to cost and timeline drift.

• Omnibus in flight: monitor the final European texts and their transposition. Calibrate the project to remain reversible if the mid-cap threshold evolves.
• VSME standard: the voluntary SME standard could become a reference for suppliers of large groups — to factor in if the company is exposed to client questionnaires.
• Articulation with the DPEF: for years still covered by the French extra-financial performance declaration, plan the transition to avoid duplication.
• Supplier data: the value chain (scope 3, duty of vigilance, responsible procurement) remains the hard point. See our piece on responsible procurement and supplier clauses.
• Consistency with financial communication: commitments made in the sustainability report must be consistent with investor decks, term sheets and bank covenants.

To structure ESG data collection, some clients use an accounting platform such as Pennylane coupled with a dedicated sustainability reporting tool.

Hayot Expertise advisory note — Before any CSRD project, take 7 days to stabilise the 8 executive decisions. It is the most profitable investment of the entire framework. Our CSRD reporting practice supports this scoping in coordination with your statutory auditor.