CSRD: Who is affected and how can you comply by 2025?
According to estimates, around 50,000 companies will be subject to CSRD by 2029, with a significant increase in the number of companies concerned as early as 2025. Are you ready?
Sustainability is no longer an option, but a necessity, particularly for the agricultural and agri-food company sector. With the progressive entry into force of the Corporate Sustainability Reporting Directive (CSRD), companies must prepare for new obligations that redefine the way they communicate their environmental, social and governance (ESG) performance.
In the course of 2025, the CSRD will apply to another category of large companies (those not subject to the NFRD*), marking a new stage in their transparency and sustainable commitment.
For the agri-food sector, which is particularly exposed to environmental and climate issues, this directive represents both a regulatory challenge and a strategic opportunity.
If you run a company in the agri/agro sector and you're wondering whether your structure is affected, what concrete actions you need to take to comply, or how to prepare a compliant sustainability report, this article will help you. This article answers all your questions and guides you through this transition.
Discover the new obligations, the key stages and our advice on how to make CSRD a lever for competitiveness and confidence in your CSR approach.
- Find out who will be affected by CSRD in 2025 and beyond.
- Which sectors are most affected
How can agri-food companies comply with the CSRD? - But also more information on the CSRD sustainability report,
- And above all, how MyEasyFarm can help you achieve CSRD compliance!
This article takes into account the proposals of the Omnibus package. The Omnibus package brings clarifications and simplifications to the CSRD directive, aimed at easing the administrative burden on companies while ensuring transparency on their sustainability commitments. These adjustments include a deferral for listed SMEs, better harmonization with the GHG Protocol and the possibility of using sectoral data when primary data is unavailable.
*Non Financial Reporting Directive
CONTENTS
1. CSRD: who is concerned in 2025?
2. What is the Corporate Sustainability Reporting Directive (CSRD) again?
3. What are the phases in the CSRD implementation schedule?
a) Phase 1: January 1, 2024 > Large companies already subject to NFRD
b) Phase 2: from 2025 > Other large companies
c) Phase 3: From 2026 > Listed SMEs
d) Phase 4: From 2028 > Large non-European companies
4. Is food-processing industry the sector most concerned by CSRD?
5. How do you comply with the CSRD when you're an agri-food company ?
a) Assess your ESG maturity level
b) Collect and structure your ESG data
c) Adopt appropriate digital tools
d) Train your teams and partners
e) Preparing transparent communication
f) CSRD, a strategic challenge for the agro-industry
6. What should the CSRD sustainability report contain?
e) Data collection and verification methodology
f) Transition strategy and action plans
7. What form should the CSRD sustainability report take?
8. Who checks the sustainability report?
9. What are the penalties for non-compliance with the CSRD?
10. Our tips for successful compliance by agri-food companies and cooperatives
1. CSRD: who is concerned in 2025?
The second stage of the CSRD roll-out began in January 2025, and now includes large companies not covered by the NFRD (Non Financial Reporting Directive) with more than 250 employees, turnover in excess of €50 million and a balance sheet in excess of €25 million*. The Omnibus project modifies this step and proposes to exclude around 80% of the companies initially covered by the CSRD. From now on, only companies with over 1,000 employees will be required to comply with these reporting obligations. This change reduces the scope of the directive, but still has a major impact on large agri-food companies and their supply chains.
This regulatory change follows in the footsteps of the large companies already subject to these obligations in 2024.
In 2025, this new obligation implies several major adaptations:
- Produce detailed reports on their environmental, social and governance impacts,
- Modernize their ESG data collection and analysis systems,
- Reorganize their teams while preserving their economic efficiency.
The aim of this gradual extension is to create a uniform sustainability reporting standard for all companies in the European Union.
However, food and beverage companies, which are heavily involved in Scope 3 reporting obligations, will benefit from the reduction in data collection requirements. In particular, the Omnibus project authorizes the use of sector data when primary data is not available, a step forward that simplifies the reporting process.
*This applies to large companies meeting two of the three criteria.
2. What is the Corporate Sustainability Reporting Directive (CSRD ) again?
The CSRD (Corporate Sustainability Reporting Directive) is a European directive in force since January 2024, replacing the former NFRD (Non Financial Reporting Directive) or DPEF in France (déclaration de performance extra-financière).
Adopted in 2022, the CSRD imposes new non-financial reporting obligations on European companies.
These regulations call for greater transparency in several key areas:
- Greenhouse gas emissions
- Impact on biodiversity
- Human rights in the supply chain
- Corporate governance
a) The CSRD has 4 objectives:
- Create a standardized and rigorous reporting framework, identical for all European companies concerned
- Fight greenwashing with reliable, verifiable data
- Accelerating the transition to a sustainable economy
- Provide stakeholders (consumers, investors) with reliable, comparable information
This harmonization of non-financial reporting makes it possible to effectively assess and compare the ESG (Environmental, Social and Governance) performance of European companies, while aligning them with the EU's climate objectives.
ESG - Environment Governance Social CSRD Regulations
3. What are the phases in the CSRD implementation schedule?
As we have just seen, the CSRD (Corporate Sustainability Reporting Directive) is being introduced gradually. Large companies already subject to the Non-Financial Reporting Directive (NFRD) have already begun publishing their reports for the 2024 financial year.
Another category of large companies (this time those not covered by the NFRD) meeting certain thresholds will also have to publish their reports in 2026, based on their activity in the 2025 financial year.
The CSRD deployment schedule will therefore be phased in from 2024 to 2029.
To give you a clearer idea of its deployment, here is a guide to its stages and impact:
"CSRD MyEasyFarm deployment schedule".
a) Phase 1: January 1, 2024 > Large companies already subject to NFRD
Who is affected?
Companies already covered by the NFRD (Non-Financial Reporting Directive), in force since 2014. This includes large companies meeting two of the following three criteria:
- More than 500 employees.
- Sales in excess of €50 million.
- Balance sheet total over €25 million and/or sales over €50,000,000
Calendar :
- Implementation: January 1, 2024.
- First report: in 2025, covering fiscal year 2024.
These companies must already have ESG (Environment, Social, Governance) processes in place and integrate the European Sustainability Reporting Standards (ESRS) to meet the new requirements.
b) Phase 2: from 2025 > Other large companies
Who is concerned?
Large companies not covered by the NFRD, meeting at least two of the following three criteria:
- More than 250 employees. (before the Omnibus package)
- Sales in excess of €50 million.
- Total assets in excess of €25 million.
Calendar :
- Implementation: January 1ᵉʳ, 2025.
- First report: in 2026, based on 2025 data.
This phase considerably broadens the scope of the CSRD, also affecting non-European companies listed on European regulated markets.
However, alignment with the EU's green taxonomy has been modified with the Omnibus package: only companies with more than 1,000 employees will have to justify the compliance of their activities with these criteria. However, for those companies that remain concerned, the integration of tools such as MyEasyCarbon can automate the collection and analysis of the data required for reporting.
c) Phase 3: From 2026 > Listed SMEs
Who is concerned?
Small and medium-sized enterprises (SMEs) listed on European regulated markets.
Calendar :
- Implementation: January 1ᵉʳ, 2026.
- First report: in 2027, based on 2026 data.
- Postponement option: these companies can request a one-year postponement, with first publication in 2028.
Listed SMEs benefit from fewer obligations than larger companies. They can request a one-year postponement to start publishing their reports.
d) Phase 4: From 2028 > Large non-European companies
Who is concerned?
Large companies not based in the European Union, but with significant activities in the EU. This includes companies with a turnover in excess of €150 million in the EU, or with significant subsidiaries in Europe.
Calendar :
- Implementation: January 1ᵉʳ, 2028.
- First report: in 2029, covering the 2028 financial year.
These companies will have to comply with the same standards as European companies, thus guaranteeing ESG transparency on an international scale.
💡In short: The CSRD timetable has been designed to enable a smooth transition to sustainability standards. Each phase ensures preparation tailored to the size and structure of companies.
This process marks an important step towards greater transparency on environmental, social and governance impacts on a European and global scale.
The above illustration does not take into account the Omnibus package to clarify and simplify the CSRD directive.
4. Is food-processing industry the sector most concerned by CSRD?
While all industries are affected, certain sectors, such as the food industry, are particularly hard hit because of their significant environmental and social footprint.
a) Agro-industries :
Large food processing groups will have to integrate emissions data from their supply chain, including agricultural activities.
b) Agricultural cooperatives :
They will play a key role in the transmission of ESG data, in particular to ensure the traceability of agricultural practices.
c) Agricultural suppliers :
Indirectly, farmers, although not directly subject to CSRD, will have to collaborate to provide data on their environmental practices (fertilization, crop rotation, etc.).
According to the European Commission:
- 50,000 companies should have been covered by the CSRD before the Omnibus reform, compared with 11,600 under the NFRD. With Omnibus, 80% of these companies are now exempt, as only those with more than 1,000 employees will be obliged to comply with CSRD.
- The agricultural sector accounts for around 10% of the EU's GHG emissions, making it a priority area for attention.
These figures illustrate how important it is for agri-food companies to prepare themselves by anticipating these new requirements.
5. How do you comply with the CSRD when you're an agri-food company ?
The CSRD (Corporate Sustainability Reporting Directive) redefines sustainability reporting requirements for European companies, including those in the agri-business sector. Its gradual adoption requires methodical preparation.
Here's a summary of the 5 key steps you need to take to comply with the directive and turn it into a lever for transformation:
a) Assess your ESG maturity level
The first step is to carry out an audit of your environmental, social and governance (ESG) practices. This diagnosis enables you to identify strengths, weaknesses and gaps in relation to the requirements of European reporting standards (ESRS). This analysis will help you structure an appropriate action plan.
b) Collect and structure your ESG data
Data collection is at the heart of CSRD compliance. In the agro-industry, this includes data on :
- Agricultural practices (carbon footprint, use of natural resources)
- Supply chain (traceability, social impact)
- Relevant financial and non-financial indicators.
💡 To guarantee reliability, it's crucial to put in place mechanisms for systematic data collection and standardization, throughout the value chain.
Agri-food companies, which are heavily involved in Scope 3 reporting obligations, will benefit from the reduction in data collection requirements. In particular, the Omnibus package authorizes the use of sector data when primary data is not available, a step forward that simplifies the reporting process.
c) Adopt appropriate digital tools
An ESG data management system is essential for centralizing, analyzing and tracking your performance.
Specialized solutions, such as those offered by MyEasyFarm, optimize the management of environmental and social impacts in the agro-industry.
Our tips for anticipating CSRD :
- Identify your compliance deadline: The CSRD applies in progressive phases. Find out whether your company is affected as early as 2025 or in a later phase.
- Analyze dual materiality: Identify the most significant social and environmental issues for your business and your stakeholders.
- Strengthen your governance: Centralize data and involve key departments (finance, IT, HR) to ensure sustainable integration of the directive's requirements.
- Invest in technological tools: Innovative solutions simplify the transition from data collection to final reporting.
d) Train your teams and partners
The success of ESG reporting depends on training:
- Internal: Teams need to master key sustainability concepts and regulatory requirements.
- External: Agricultural partners, often the first suppliers of data, must understand the importance of providing accurate and reliable information.
💡 Widespread skills upgrading is essential to meet European standards.
e) Preparing transparent communication
Beyond compliance, the sustainability report is a strategic tool. It enables you to showcase your efforts to stakeholders (investors, consumers, regulators) and strengthen your reputation.
💡 Take a proactive approach and highlight your ESG advances clearly and honestly.
f) CSRD, a strategic challenge for the agro-industry
The agro-industry is particularly concerned by the requirements of the CSRD, due to its direct impact on natural resources and ecosystems. Complying with this directive is not only a regulatory obligation, but also an opportunity for sustainable transformation.
💡 Adopt a proactive approach today to turn this constraint into a competitive lever.
Would you like to find out more and talk to our experts?
6. What should the CSRD sustainability report contain?
The CSRD sets standards and obligations that companies must include in their annual non-financial reporting. To put it plainly, it requires them to monitor and publish, in addition to their financial balance sheet, an ESG balance sheet giving as much importance to the sustainable dimension as to the economic dimension of their activities!
Here are the main elements of the report:
a) Dual materiality analysis
The dual materiality analysis assesses 2 points:
- Financial materiality: how environmental and social issues affect a company's financial performance and prospects.
- Impact materiality: how a company's activities impact society and the environment.
This analysis enables us to identify the significant issues to be included in the report.
b) On the environmental side
Companies must detail their carbon footprint (including scopes 1-2-3emission ), their resource management and their impact on biodiversity...
With the Omnibus package, companies can use more flexible estimates if they don't have precise data on their Scope 3 emissions.
It covers working conditions, equal opportunities, health and safety, and skills development. Particular attention is paid to human rights throughout the value chain.
d) Governance
The report must present the company's sustainability strategy, objectives and control mechanisms. Transparency on business ethics and risk management is essential.
e) Data collection and verification methodology
Companies must also explain how ESG data is collected, centralized and verified.
💡 Please note that the report must be audited by an independent third party to guarantee its reliability.
f) Transition strategy and action plans
The case must include the company's plans for transition to a low-carbon economy, efforts to improve the sustainability of value chains, and investments made or planned to achieve ESG objectives.
7. What form should the CSRD sustainability report take?
The sustainability report will have to be integrated into the company's management report, with the obligation to digitally tag the information declared according to the taxonomy system defined by the European Commission (digital categorization system).
Eventually, the case will have to be integrated into the European company information platform, ESAP(European Single Access Point), whose operational deployment phases are still unclear.
With the Omnibus package, a less binding but still strategic sustainability report!
✅ For large companies: still concerned, but with relaxed requirements.
✅ For SMEs and agricultural suppliers: less pressure to provide data, but a strategic issue if they want to collaborate with large companies.
✅ For the food industry: Scope 3 reporting remains key, but flexibility of calculation methods is increased.
8. Who checks the sustainability report?
The sustainability report can be verified by :
- A statutory auditor
- Or an independent third-party organization (ITO) appointed by the company.
ITOs must be accredited by COFRAC (Comité français d'accréditation).
💡 Please note that the sustainability report will have to be updated and checked every year.
9. What are the penalties for non-compliance with the CSRD?
Penalties for non-compliance with CSRD requirements are determined by each Member State.
In France, according to the transposition order published in the Official Journal on December 7, 2023, the following fines apply to CSRD:
- Failure to publish the report or publication of partial or erroneous information: 3,750 euros fine
- Failure to audit the sustainability report: a fine of 30,000 euros and two years' imprisonment for the company director.
- Obstructing auditors' verifications or controls: a fine of 75,000 euros and up to five years' imprisonment for the company director.
💡 Beyond the legal penalties, failure to publish or audit your sustainability report can have a significant impact on your company's reputation. The trust placed in you by stakeholders, particularly your investors, customers and suppliers, is likely to "take a hit". What's more, some private markets may become inaccessible to companies that fail to meet their sustainability obligations.
The aim of the CSRD is to encourage companies to become more involved. Let's bet that only the best will come out on top!
10. Our tips for successful compliance by agri-food companies and cooperatives
In a word: Anticipate! Compliance is a time-consuming process, and a real challenge for the companies involved.
To meet the deadline, you can now analyze your environmental impact and prepare your CSR strategy by following these steps:
- Rely on external skills to carry out the carbon footprint, ESG criteria monitoring and CSR strategy...
- Start by drawing up a balance sheet focusing on your company's upstream agricultural scope.
- Start a dialogue with stakeholders (gather information from suppliers, find subcontractors with a low-carbon approach, etc.).
11. MyEasyFarm can help you achieve CSRD compliance
MyEasyFarm, a specialist in regenerative, low-carbon agriculture, supports players in the agri-food chain at every stage of CSRD compliance.
Our key solutions:
- Regenerative agriculture: data collection and monitoring of supply chain projects promoting change towards more sustainable practices.
- Low-carbon reporting: facilitate data collection and analysis with calculation tools adapted to certified projects (Label Bas-Carbone, Verra Standard, Carbon Certificates).
- Innovative digital tools: Integrate the latest technologies for accurate and efficient ESG monitoring (sensors, remote sensing, automated data management).
Our strengths :
- Customized support for agri-food companies, cooperatives and their partner farmers.
- Expertise dedicated to managing complex agricultural data.
- A recognized Tier 2 tool for GHG emissions and Tier 3 for carbon sequestration, already used by many agro-industrial companies.
Since its creation in 2017, MyEasyFarm has established itself as a key player in the agro-ecological transition by offering advanced digital solutions for managing and exploiting agricultural data.
Faced with the growing demands of the CSRD (Corporate Sustainability Reporting Directive ), MyEasyFarm enables agri-food companies and cooperatives to measure, manage and improve their environmental impact, particularly in terms of Scope 3 greenhouse gas emissions.
Thanks to automated, interoperable primary data collection (Satelite, sensors, machine and weather data), MyEasyFarm simplifies access to accurate, reliable information, reducing dependence on declarative data.
The integration of the audited companies' internal databases and the selection of the most appropriate secondary data guarantee a rigorous assessment in line with international standards (GHG Protocol, SBTi).
Finally, with its collaborative approach and certified MRV (Measure, Report, Verify) platform, MyEasyFarm ensures total data transparency while facilitating the implementation of sustainability strategies aligned with European regulations.
Would you like to find out more and talk to our experts?
Why act now?
As we saw earlier, compliance with the CSRD must be seen as a strategic opportunity, not a constraint.
It will enable you to :
- Meeting consumer and investor expectations in terms of sustainability,
- Strengthen transparency and trust in your business relationships,
- Transform your practices into competitive advantages.
Expert advice
We recommend that you plan ahead as far as possible. Preparing for the CSRD is a demanding process, requiring time, commitment and rigorous attention due to its regulatory nature. It's also essential to start building up your database as soon as possible, as collecting indicators is a time-consuming process.
Tiphaine Robert - Agricultural engineer
The Omnibus reduces obligations for European companies, especially SMEs and mid-sized companies, but maintains high requirements for large companies and financial players.
CCL: What if CSRD became your strategic asset?
Far from being a mere constraint, the CSRD directive paves the way for a positive transformation. It's an opportunity to rethink your practices, anticipate the expectations of your customers and partners, and stay one step ahead of your competitors.
In a sector as exposed as the agro-industry, getting ready now means staying competitive while contributing to environmental practices that are more respectful of resources and ecosystems. Make this directive a catalyst for progress for your teams, your partners and your global impact.
With the right support and innovative tools like those offered by MyEasyFarm, your company can turn this challenge into a real strategic success.
The question is no longer whether you should act, but how you can take advantage today.
So, ready to take up the challenge? Let's take action!
Take action today with MyEasyFarm!
📩 Contact us now so that our teams can show you how MyEasyFarm can help you comply with the CSRD directive.
Don't let regulations overtake you. Turn CSRD into a sustainable, high-performance transformation lever with MyEasyFarm. 🚀
c) Social aspects