CSR and CSRD Reporting White Paper: The 2026 Business Guide

Before discussing methodology, let us consider the scale. The "Omnibus" package adopted by the European Union dramatically narrows the CSRD's scope: only companies with more than 1,000 employees and more than €450 million in annual revenue remain in scope, meaning roughly 80% of previously covered companies fall out^[1]. The "Stop the Clock" directive, which entered into force on 18 April 2025, also defers application to second-wave companies by two years, now expected to report on the 2027 financial year^[2]. The simplification is real, but the obligation remains for the groups that matter.

On the standards side, the ESRS adopted by the European Commission in December 2023 articulate 12 standards (2 cross-cutting and 10 topical) that break down into 84 disclosure requirements and approximately 1,144 data points^[3]. The scale explains why corporate CSRD reporting cannot be handled at year-end: the bulk of the work lies in the double materiality assessment and upstream data collection, not in the final write-up. And on the climate side, the data speaks for itself: scope 3 emissions account for an average of 75% of a company's total footprint^[4], and sometimes more than 90% for food groups tested by the GHG Protocol^[5]. Any CSR approach that ignores this perimeter misses the point entirely.

1. The CSRD framework and ESRS standards. The CSRD requires in-scope companies to publish a sustainability report alongside their annual accounts, in accordance with the ESRS and subject to a limited assurance audit. The 2025 Omnibus package raised the thresholds to 1,000 employees and €450 million in annual revenue^[1], and an agreement between the three European institutions in December 2025 confirmed simplified requirements. The lesson is not "less CSR" but "less empty reporting": for companies that remain in scope, the structuring effort is unchanged. This is what our analysis details on what the CSRD changes for mid-sized companies in France.

2. Double materiality. This is the cornerstone of the ESRS. A company must assess each topic from two angles: impact materiality (the effect of its activities on the environment and society) and financial materiality (the effect of sustainability issues on its performance). Only information deemed material under this double criterion needs to be disclosed^[6]. In practice, this analysis is not conducted in a management meeting: it mobilises internal and external stakeholders, documents the methods used, and prioritises topics. It is what transforms a declarative CSR approach into a manageable system, and what shields companies from greenwashing accusations.

3. Scopes 1, 2 and 3 of the GHG Protocol. The GHG Protocol is the global standard for emissions accounting, and it structures the carbon inventory behind the ESRS. Scope 1 covers direct emissions (on-site combustion, owned fleet), scope 2 covers indirect emissions related to purchased energy (electricity, heat), and scope 3 covers other indirect emissions across the value chain: purchases of goods and services (category 1), business travel (category 6), upstream transport, use of sold products^[7]. This last perimeter carries the lion's share of emissions. The reference guide remains our practical guide to scopes 1, 2 and 3 in business.

4. The carbon footprint assessment. The French regulatory greenhouse gas (GHG) assessment, governed by Article L. 229-25 of the Environmental Code and Decree No. 2022-982, applies to private legal entities with more than 500 employees in metropolitan France (250 in overseas territories), with renewal every four years^[8]. The BEGES-R method requires precise granularity by category. But the value of a carbon footprint assessment goes beyond legal compliance: it is the snapshot that reveals where to act. An assessment without an action plan is a dead document; one that feeds a decarbonisation roadmap becomes a strategic management tool.

5. Decarbonisation and carbon offsetting. The order is immutable: measure, reduce, and then offset, as a last resort for irreducible residual emissions. Offsetting can never substitute for actual emissions reductions, and regulators as well as standard-setters (SBTi, GHG Protocol) are explicit on this point^[9]. A strategy that begins with offsetting before mapping emissions loses all credibility. To build a credible plan, an inventory of available tools is worthwhile: our top 10 tools to reduce your company's carbon footprint covers the operational levers.

6. Measurable impact. This is the final test. A CSR approach that does not translate into tracked indicators, compared year on year, remains window dressing. Corporate CSRD reporting imposes precisely this discipline: data traceability, consistent calculation methods, year-on-year comparability. And when an associated giving programme is in place (such as the 1%ForAll® programme, which allocates 1% of every transaction to the Greenway Foundation), impact is measured in euros donated and projects funded, not intentions.

Most CSR approaches suffer from the same flaw: they rely on data reconstructed after the fact. As the deadline approaches, teams gather disparate files, multiply assumptions, and produce an approximate assessment that satisfies the formality without informing decision-making. The cost is not just time. It is credibility. A statutory auditor reviewing manually reconstructed data will ask questions. An investor comparing two financial years with shifting perimeters will conclude there is a lack of transparency.

The concrete challenge is scope 3. Purchases of goods and services and business travel account for the majority of indirect emissions, and they are calculated from spend data itself: a supplier purchase, a train ticket, a hotel night. A company that categorises its expenses as they arise already holds usable raw material for its carbon inventory. One that reconciles everything annually pays for data collection every year. Sustainability starts here, with exploitable spend data, as illustrated by our approach to the corporate card in service of CSR.

Carbon offsetting is arguably the most poorly handled topic in CSR. Presented as a solution, it has become a communication marker, and conversely the systematic target of criticism. The reality comes down to a hierarchy: reduce first, offset second. Buying credits against a perimeter you have not measured is building a roof without walls.

Technically, the quality of an offset credit is judged against three criteria: additionality (the project would not have existed without the financing), permanence (the stored carbon does not re-enter the atmosphere), and the absence of leakage (a reduction on one side does not create an emission elsewhere). Serious standards (the French low-carbon label, international certifications) address these points. The SBTi is clear that credits do not count towards the reduction trajectory: they cover the residual, they do not replace it^[9].

This is the line that separates credible approaches from the rest. A company that publishes its scopes, its trajectory, and additionally runs an offsetting programme for its residual emissions tells a coherent story. A company that displays credits with no carbon assessment has nothing to say.

If scope 3 accounts for 75% of the average footprint, it is not by chance: that is where procurement, upstream logistics and business travel live. The operational consequence is direct: everything that structures spend and mobility data also structures climate reporting. A fleet managed down to the litre, categorised expense reports, a fuel card that isolates fuel spend: each of these levers feeds both management control and the carbon inventory.

This is the blind spot for many finance departments. Spend is treated as an accounting object, carbon as a CSR object. In practice, they share the same raw material. The integrated approach means categorising once, to serve two outputs: accounting and the GHG inventory. On this model, the corporate card in service of CSR illustrates how a single payment instrument feeds scope 3 without double entry.

Scope 3 calculation relies, in the absence of primary supplier data, on emission factors applied to amounts spent. The finer the spend category, the more accurate the result. The more aggregated it is, the wider the approximation. This is why a poorly categorised expense produces an approximate carbon assessment. It is also why structuring a spend reference framework is a CSR investment, not just a finance one.

To move from declarative CSR to a defensible report, seven concrete checks make all the difference:

The CSRD does not stand alone. It sits within a coherent regulatory edifice: French Decree No. 2022-982 on GHG assessments^[8], the CS3D directive on corporate due diligence, the European greenwashing regulation, and the French Climate and Resilience Act with its criminal provisions on eco-washing. Taken together, these texts state a simple rule: what is published must be provable. The era of communicational CSR is closing.

The Omnibus package eased the timeline, but it did not reverse the trend. Thresholds have been raised, the second wave delayed^[2], the ESRS are being simplified, and yet large companies remain required to produce structured, audit-subject reporting aligned with a European framework. For a large group, preparing for the CSRD is no longer a peripheral compliance topic: it is an information systems project.

The same principle applies to suppliers of in-scope companies. An SME that is not itself subject to the CSRD will nonetheless be asked by its clients for its emissions data — this is the value chain effect inherent to scope 3. CSR propagates through the supply chain: better to structure your spend and energy data before your client demands it.