If your company exports to the European Union — or sits anywhere in a European company's supply chain — a regulation called CSRD is about to change your reporting obligations. Not eventually. Starting now.
The EU's Corporate Sustainability Reporting Directive is the most ambitious sustainability disclosure law in the world. And while it's a European regulation, its reach extends deep into Indian industry — particularly in manufacturing, chemicals, textiles, pharma, and IT services.
What Is CSRD?
The Corporate Sustainability Reporting Directive is an EU regulation that requires companies to publish detailed sustainability reports following a new set of standards called ESRS (European Sustainability Reporting Standards).
It replaces the older Non-Financial Reporting Directive (NFRD), which covered about 11,000 EU companies. CSRD expands this to roughly 50,000 companies — and critically, it includes non-EU companies with significant European operations or revenue.
Effective: Phased rollout from 2024 to 2028, depending on company size
Standards: ESRS (12 standards covering climate, pollution, biodiversity, workforce, governance, and more)
Assurance: Third-party audit required (limited assurance initially, moving to reasonable assurance)
Scope: Requires value chain data — meaning your EU clients will ask you for sustainability information
The CSRD Timeline
| Financial Year | Who Reports | First Report Due |
|---|---|---|
| 2024 | Large EU public-interest entities (already under NFRD) | 2025 |
| 2025 | All large EU companies (250+ employees, EUR 50M+ revenue) | 2026 |
| 2026 | Listed EU SMEs (with opt-out until 2028) | 2027 |
| 2028 | Non-EU companies with EUR 150M+ EU net turnover | 2029 |
The 2025-2026 wave is the one that hits Indian exporters hardest — not because Indian companies report directly, but because their EU clients will need value chain sustainability data for the first time.
How CSRD Impacts Indian Companies
CSRD affects Indian businesses through two channels:
1. Indirect Impact: Supply Chain Data Requests (2025-2026)
When an EU company reports under CSRD, it must disclose sustainability data across its entire value chain — including suppliers. If you're an Indian manufacturer, chemical supplier, IT outsourcing partner, or textile exporter serving EU clients, expect to receive detailed sustainability questionnaires covering:
- Scope 3 emissions data — your carbon footprint becomes part of their reporting
- Environmental practices — water use, waste management, pollution controls
- Social metrics — labor conditions, health and safety, living wages, diversity
- Governance — anti-corruption policies, supply chain due diligence
- Double materiality — how sustainability issues affect your business and how your business affects people and planet
If you can't provide this data, your EU client may need to disclose that gap — or find a supplier who can. CSRD is quietly becoming a procurement filter.
2. Direct Reporting Obligation (from 2028)
Non-EU companies meeting all three of these criteria will need to file CSRD reports directly:
- EUR 150 million+ net turnover in the EU (across two consecutive years)
- At least one EU subsidiary or branch
- The subsidiary exceeds EUR 40M turnover or the branch exceeds EUR 8M
This will apply to a smaller set of large Indian companies — but if your EU revenue is growing, this threshold may come into view sooner than expected.
CSRD vs BRSR: How Do They Compare?
Indian companies already reporting under BRSR have a head start — but the two frameworks differ significantly in depth and scope.
| Dimension | BRSR (India) | CSRD / ESRS (EU) |
|---|---|---|
| Regulator | SEBI | European Commission |
| Applicability | Top 1,000 listed Indian companies | ~50,000 EU companies + qualifying non-EU companies |
| Framework | 9 NGRBC principles | 12 ESRS standards |
| Materiality | Single materiality | Double materiality (impact + financial) |
| Value chain data | Limited | Extensive (upstream + downstream) |
| Assurance | Phasing in (BRSR Core) | Mandatory from day one |
| Emission scopes | Scope 1 & 2 (Scope 3 encouraged) | Scope 1, 2, & 3 (mandatory) |
| Climate transition plan | Not required | Required (Paris-aligned) |
The gap that matters most for Indian exporters: value chain data and Scope 3 emissions. BRSR doesn't require the level of supply chain disclosure that your EU client now needs from you.
Which Indian Industries Are Most Affected?
Any sector with significant EU export exposure faces CSRD-driven data requests. The most impacted:
- Textiles & Apparel — EU fashion brands are early adopters of supply chain sustainability reporting. Expect detailed questionnaires on labor, water, chemicals, and carbon footprint
- Chemicals & Petrochemicals — GHG Protocol data, pollution metrics, and REACH compliance overlap
- Pharmaceuticals — API suppliers and contract manufacturers are deep in EU pharma value chains
- IT & Business Services — outsourcing partners need to provide energy use, workforce diversity, and governance data
- Auto Components — EU OEMs are cascading CSRD requirements through their tier-1 and tier-2 suppliers
- Agriculture & Food Processing — deforestation-free supply chain rules compound with CSRD disclosure
How to Prepare: A Practical Roadmap
You don't need to become an ESRS expert overnight. But you do need to start building the data infrastructure that your EU clients will require.
Step 1: Map your EU exposure. Identify which EU clients report under CSRD and when. Understand what data they'll need from you and by when.
Step 2: Baseline your emissions. Conduct a Scope 1, 2, and 3 carbon audit. This is the single most requested data point. Use our Carbon Calculator for a quick estimate.
Step 3: Run a double materiality assessment. Identify which ESG topics are material to your business — both in terms of financial impact on your company and your company's impact on people and environment.
Step 4: Align your data systems. Set up internal processes to collect, verify, and report sustainability data on an annual cycle. If you're already doing BRSR, extend your data collection to cover ESRS gaps.
Step 5: Get ahead of assurance. CSRD requires third-party assurance. Even if you're not directly reporting, having auditable data gives your EU clients confidence and strengthens your position as a preferred supplier.
The Strategic Opportunity
CSRD compliance isn't just a cost — it's a competitive advantage. Indian exporters who can readily provide verified sustainability data will be preferred over competitors who can't. As EU procurement teams increasingly use CDP scores and CSRD readiness as vendor selection criteria, early movers gain a tangible commercial edge.
Companies that align with both BRSR (for Indian regulators) and CSRD (for EU clients) position themselves at the intersection of two of the world's most important sustainability disclosure regimes — and that's a story investors, clients, and regulators all want to hear.
Frequently Asked Questions
Yes, in two ways. Indian companies in EU supply chains will face data requests from their EU clients who must report under CSRD. Additionally, Indian companies with EUR 150M+ EU net turnover may need to report directly from 2028.
The indirect impact begins in 2025-2026, when large EU companies start reporting and request value chain sustainability data from their Indian suppliers. Direct reporting obligations for qualifying non-EU companies begin from financial year 2028.
BRSR is India's SEBI-mandated ESG disclosure for listed companies, based on nine NGRBC principles. CSRD uses ESRS standards — more granular, requiring third-party assurance, double materiality, and extensive value chain data. BRSR is a good starting point, but CSRD requires significantly more detail.
Start by mapping which EU clients report under CSRD. Conduct a Scope 1, 2, and 3 emissions audit, perform a double materiality assessment, and align your data collection with ESRS requirements. Companies already compliant with BRSR have a head start but need to fill gaps in value chain reporting.
Need help with CSRD readiness?
Our team helps Indian exporters bridge the gap between BRSR and CSRD — from baseline audits to ESRS-aligned reporting. Based in Gujarat, serving exporters across India.
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